G.R. No. 184295 July 30, 2014
NATIONAL TRANSMISSION CORPORATION, Petitioner, vs. ALPHAOMEGA INTEGRATED CORPORATION, Respondent.

FACTS

Respondent Alphaomega Integrated Corporation (AIC), a transmission line contractor, was awarded six government construction projects by petitioner National Transmission Corporation (TRANSCO). During performance, AIC encountered difficulties and incurred losses allegedly due to TRANSCO’s breach of contract, including failure to: (a) furnish required Detailed Engineering; (b) arrange a well-established right-of-way; (c) secure necessary permits and clearances from LGUs; (d) ensure a continuous supply of construction materials; and (e) carry out requests for power shutdown. These issues caused protracted delays and contract suspensions, leading AIC to surrender the projects under protest. In accordance with an arbitration clause in the contracts, AIC filed a request for arbitration before the Construction Industry Arbitration Commission (CIAC), seeking contract rescission and payment of actual and compensatory damages, among others. TRANSCO countered that it had conducted Detailed Engineering and obtained necessary permits, and alleged that AIC was guilty of frontloading and had disregarded workable portions of the projects. The CIAC Arbitral Tribunal rendered a Final Award ordering TRANSCO to pay AIC a total of ₱17,495,117.44 as actual and compensatory damages. TRANSCO filed a petition for review with the Court of Appeals (CA). Before filing its comment, AIC moved for the issuance of a writ of execution for an increased amount of ₱18,967,318.49, seeking correction of discrepancies between the dispositive portion and the body of the Final Award. The Arbitral Tribunal denied the motion for being filed beyond the 15-day period under the CIAC Rules. The CA affirmed the CIAC’s factual findings but modified the total award to ₱18,896,673.31, noting a mathematical error in the computation. TRANSCO’s motion for reconsideration was denied.

ISSUE

1. Whether the CA erred in affirming the CIAC Arbitral Tribunal’s findings that AIC was entitled to damages as a result of project delays.
2. Whether the CA erred in increasing the total amount of compensation awarded in favor of AIC despite AIC’s failure to raise the allegedly erroneous computation before the CIAC in a timely manner.

RULING

The Supreme Court denied the petition. On the first issue, the Court held that the question raised by TRANSCO—whether AIC was entitled to damages—was factual in nature. A petition for review on certiorari under Rule 45 shall raise only questions of law. Absent any exceptional circumstances, the Court is precluded from re-examining factual determinations. The CIAC’s factual findings, as affirmed by the CA, are final and conclusive. On the second issue, the Court found that the CA correctly rectified the mathematical error in the CIAC’s Final Award. While AIC’s motion for correction was filed out of time with the CIAC, the CA, in the exercise of its appellate jurisdiction, had the authority to review every aspect of the case, including the correction of evident miscalculations. The dispositive portion of a decision controls when there is a conflict with the body of the decision. In this case, the body of the CIAC’s Final Award contained the detailed computation supporting a total award of ₱18,896,673.31, which conflicted with the ₱17,495,117.44 stated in the dispositive portion. The CA properly corrected this discrepancy to reflect the true intent of the arbitral tribunal.