G.R. No. 187552-53, October 15, 2019
SHANGRI-LA PROPERTIES, INC. (NOW KNOWN AS SHANG PROPERTIES, INC.) V. BF CORPORATION; BF CORPORATION V. SHANGRI-LA PROPERTIES, INC. (SLPI), NOW KNOWN AS EDSA PROPERTIES HOLDINGS, INC., ET AL.

FACTS

This case involves a Concurring Opinion by Justice Andres B. Reyes, Jr. regarding the scope of appellate review of decisions from the Construction Industry Arbitration Commission (CIAC). The main issue stems from conflicting views on whether appeals from CIAC decisions to the Court of Appeals (CA) under Rule 43 are limited to questions of law or may include questions of fact. The ponencia (written by Chief Justice Lucas P. Bersamin) upheld a comprehensive scope of review for the CA, including factual inquiries. A Separate Opinion (by Justice Leonen) took the view that appeals are limited to questions of law. Justice Reyes concurs with the ponencia but writes separately to address the statutory basis for the broader scope of review.

ISSUE

Whether the Court of Appeals, in reviewing decisions of the Construction Industry Arbitration Commission (CIAC) under Rule 43 of the Rules of Court, has the power to resolve questions of fact, or is its review limited solely to questions of law.

RULING

The Concurring Opinion rules that the Court of Appeals has the power to resolve questions of fact in appeals from CIAC decisions. This power is grounded in Republic Act (R.A.) No. 7902, which amended the Judiciary Reorganization Act (B.P. Blg. 129) to grant the CA “exclusive appellate jurisdiction” over awards of quasi-judicial agencies and explicitly gave it the “power to try cases and conduct hearings, receive evidence and perform any and all acts necessary to resolve factual issues raised in cases falling within its original and appellate jurisdiction.” This statutory grant is implemented by Rule 43 of the 1997 Rules of Civil Procedure, which specifically lists the CIAC among the quasi-judicial agencies covered and states in Section 3 that an appeal under this Rule may be taken to the CA “whether the appeal involves questions of fact, of law, or mixed questions of fact and law.” The opinion rejects the view that Section 3 of Rule 43 merely recognizes historical variances in modes of appeal, emphasizing that the plain meaning of the statute and rule must be applied. It cites jurisprudence (Metro Construction Inc. v. Chatham Properties, Inc. and J Plus Asia Dev’t Corp. v. Utility Assurance Corp.) confirming that the enactment of R.A. No. 7902 and the promulgation of the 1997 Rules effectively broadened the scope of appeal from CIAC awards to include questions of fact, modifying the earlier procedure under Executive Order No. 1008 (the Construction Industry Arbitration Law) which limited appeals to the Supreme Court on pure questions of law.