GR 172525; (October, 2010) (Digest)
G.R. No. 172525 ; October 20, 2010
SHINRYO (PHILIPPINES) COMPANY, INC., Petitioner, vs. RRN INCORPORATED, Respondent.
FACTS
Petitioner Shinryo and respondent RRN entered into a subcontract agreement for electrical works on the Phillip Morris Greenfield Project. Respondent could not complete the works due to financial difficulties. Petitioner paid a total of ₱26,547,624.76. Respondent filed a claim with the Construction Industry Arbitration Commission (CIAC) to recover an alleged unpaid balance of ₱5,275,184.17, covering unpaid subcontract portions, variations, and unused materials. Petitioner filed a counterclaim for overpayment, asserting deductions for material back charges and equipment rental, including for a manlift.
The CIAC ruled in favor of respondent, ordering petitioner to pay ₱3,728,960.54 plus legal interest. The CIAC disallowed petitioner’s claim for manlift rental charges, finding no agreement supporting such a charge, and awarded respondent the value of certain inventoried materials. The Court of Appeals affirmed the CIAC decision. Petitioner elevated the case, arguing the CA erred in denying the manlift rental claim and in affirming the award for inventoried materials.
ISSUE
Whether the Court of Appeals erred in affirming the CIAC’s factual findings which denied petitioner’s claim for manlift equipment rental and awarded respondent the value of inventoried materials.
RULING
The Supreme Court denied the petition and affirmed the CA. On the manlift rental, the Court upheld the CIAC’s finding that petitioner failed to prove the existence of an agreement obligating respondent to pay for the manlift’s use. The CIAC’s conclusion was based on evidentiary assessment, noting the absence of any written contract or purchase order for the equipment rental. Factual findings of quasi-judicial bodies like the CIAC, when affirmed by the CA, are generally conclusive and binding. The Court will not re-evaluate evidence absent a showing of grave abuse of discretion, which was not present.
Regarding the inventoried materials, the Court found no reason to disturb the CIAC’s award. The CIAC determined these materials were supplied by respondent but not installed, entitling respondent to their value. Petitioner’s argument that respondent admitted deductions for material supply was unavailing, as the CIAC interpreted the admission as not covering these specific inventoried items. The arbitral tribunal’s expertise in evaluating technical evidence is accorded respect. The awards for interest and arbitration costs were also upheld as legally sound. Thus, no reversible error was committed by the lower tribunals.