Case Summary (G.R. No. 198998)
Key Dates
– 1994: Contract commencement (alleged five-storey initial scope).
– May 18, 1998: Accomplishment billing prepared by YBC.
– August 13, 1998: YBC filed collection complaint in RTC Cebu.
– November 21, 2008: RTC rendered judgment in favor of YBC.
– June 28, 2011: Court of Appeals (CA) reversed RTC and dismissed the complaint.
– June 19, 2019: Supreme Court resolution denying YBC’s petition for review.
Applicable Law
– 1987 Philippine Constitution (decision post-1990).
– Rules of Court: Rule 8 (Pleadings and actionable documents), Rule 45 (Certiorari), Rule 130 (Best Evidence), Rule 132 (Documentary proof).
– Civil Code provisions on contracts and extra-contractual obligations.
Contractual Arrangement and Monetary Claims
YBC alleged that in 1994 it was engaged on an accomplishment-billing basis to build BII’s commercial structure. By May 18, 1998, YBC claimed total work amounting to ₱54,022,551.39, of which BII paid ₱40,678,430.00, leaving a balance of ₱13,344,121.39. YBC further asserted unpaid extra works of ₱11,839,110.99 (net ₱11,488,230.89) for a total collectible of ₱24,832,352.38. Despite repeated demands, BII allegedly defaulted.
Respondent’s Denials and Offsets
BII admitted engaging YBC but denied an accomplishment-billing arrangement, claiming instead a timetable-based contract which YBC breached by delay, abandonment, and defective workmanship. BII characterized all additional works as remedial, offsetting any payable amount against YBC’s liabilities for defects and delays.
Proceedings in the Regional Trial Court
After pretrial, YBC presented one witness (its Vice-President, architect Nelson Go Yu) and offered documentary evidence, including the Accomplishment Billing. BII’s demurrer to evidence was denied. BII then introduced five witnesses to contest completion, quality, and amounts claimed. On November 21, 2008, the RTC found in favor of YBC, awarding ₱24,832,352.38 plus interest, attorney’s fees, and litigation expenses.
Proceedings in the Court of Appeals
On appeal, the CA held that YBC failed to prove its monetary claim. It deemed the Accomplishment Billing a self-serving private document lacking authentication, excluding it under Rule 132. Without it, YBC’s collection cause lacked evidentiary support. The CA also excluded other private writings (Ernesto Dacay letter, Mary Dacay certification) for failure to comply with the Best Evidence Rule and authentication requirements. The CA reversed and dismissed the complaint.
Issues on Supreme Court Review
YBC’s petition raised whether the CA erred in:
- Disregarding Rule 8’s specific-denial requirement to admit the Accomplishment Billing.
- Ruling that the Ernesto Dacay letter was unauthenticated.
- Disregarding the Mary Dacay certification.
Supreme Court’s Ruling
- Rule 45 limits certiorari to questions of law; factual findings of the CA are conclusive except in rare conflicts.
- Accomplishment Billing not an “actionable document” under Rule 8 because it did not form the basis of the contract but merely evidenced performance. Consequently, BII was not bound to specifically deny its genuineness under oath.
- E
Case Syllabus (G.R. No. 198998)
Facts
- On August 13, 1998, Young Builders Corporation (YBC) filed with the Regional Trial Court (RTC), Branch 21 in Cebu City, a complaint for collection of a sum of money against Benson Industries, Inc. (BII).
- YBC alleged it was contracted by BII in 1994 to construct BII’s commercial building (Escario St. corner F. Ramos Extension, Cebu City) on an accomplishment-billing basis.
- As of May 18, 1998, YBC claimed it accomplished work valued at ₱54,022,551.39 under the main contract, of which ₱40,678,430 had been paid, leaving ₱13,344,121.39 unpaid.
- YBC also performed extra works amounting to ₱11,839,110.99, less ₱350,880 for a water cistern, for a total claimed collectible of ₱24,832,352.38.
- BII answered, admitting the contract but denying the accomplishment-billing arrangement; it asserted YBC’s delays, abandonment, defective workmanship, and claimed remedial work only, asserting set-off for damages.
RTC Proceedings and Decision
- YBC presented one witness, Architect Nelson Go Yu, and offered documentary exhibits including the Accomplishment Billing (Exh. B).
- BII moved a demurrer to evidence; the RTC denied it, ordering BII to present counter-evidence.
- BII then presented five witnesses to support its defenses.
- On November 21, 2008, the RTC rendered judgment in favor of YBC, ordering BII to pay:
• ₱24,832,352.38 plus legal interest from filing;
• ₱500,000.00 attorney’s fees; and
• ₱100,000.00 litigation expenses. - BII appealed to the Court of Appeals (CA).
CA Decision and Resolution
- On June 28, 2011, the CA reversed and set aside the RTC judgment and dismissed YBC’s complaint.
- The CA found YBC failed to prove its entitlement to any balance:
• The Accomplishment Billing (Exh. B) was the sole basis of its monetary claim but wa