GR 243317; (August, 2025) (Digest)
G.R. No. 243317, August 04, 2025
FLORANTE G. AGUILA, COMGLASCO AGUILA GLASS CORPORATION AND VALIENTE SELECT VENTURE, INC., PETITIONERS, vs. PERFECT DIMENSION CORPORATION, ENGR. RONALDO S. GUEVARRA AND ENGR. MARK LUMBAY, RESPONDENTS.
FACTS
Comglasco engaged Perfect Dimension Corporation (PDC) to perform fit-out works for a unit in Discovery Primea, Makati City, under a Letter of Award dated August 1, 2014, with a contract price of PHP 7,880,000.00 and a 150-day completion period from downpayment release, with provisions for liquidated damages for delay. Petitioners paid a downpayment on July 31, 2014, but actual work commenced only on November 3, 2014, after securing clearance from the building administrator. The works remained unfinished by the deadline of December 29, 2014. Petitioners terminated PDC’s services in December 2015 and hired another contractor to complete the project. Petitioners also engaged Engr. Mark Lumbay for project management services under a separate agreement. After unresolved demands, petitioners filed a complaint with the Construction Industry Arbitration Commission (CIAC) against PDC, Engr. Ronaldo Guevarra, and Engr. Lumbay, claiming liquidated damages, actual damages for defective works, costs for the new contractor, unrealized profits, return of fees from Engr. Lumbay, moral damages, and attorney’s fees.
The CIAC, in its Final Award, found both parties responsible for the delay. It allocated 56.67 days of delay to petitioners and 28.33 days to PDC/Engr. Guevarra out of an initial 85-day delay caused by late submission of requirements to the building administrator. For the remaining delay, the CIAC excused PDC et al. for 240 days due to change orders and late material deliveries by petitioners, holding them liable for only an additional 48 days, totaling 76.33 days. The CIAC awarded liquidated damages of PHP 601,480.40 against PDC. It denied all other claims of petitioners for lack of sufficient evidence, including claims for defective works and against Engr. Lumbay, whom it found to have complied with his obligations. The CIAC also granted counterclaims of PDC for unpaid billings (PHP 2,246,605.80) and of Engr. Guevarra and Engr. Lumbay for moral damages, attorney’s fees, and unpaid fees. After set-off, the CIAC ordered petitioners to pay net amounts to PDC, Engr. Guevarra, and Engr. Lumbay. The Court of Appeals affirmed the CIAC’s ruling with modifications, increasing PDC’s liability for delay to 133 days and the liquidated damages to PHP 788,000.00. Petitioners elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the Court of Appeals erred in affirming the findings and conclusions of the Construction Industry Arbitration Commission (CIAC).
RULING
The Supreme Court denied the petition. It held that factual findings of quasi-judicial agencies like the CIAC, when affirmed by the Court of Appeals, are generally conclusive and binding upon the Court. The Court found no compelling reason to deviate from this rule, as petitioners failed to sufficiently establish that the CIAC and the CA committed grave abuse of discretion or misapprehended the facts. The Court emphasized that it is not a trier of facts and will not re-evaluate evidence in a Rule 45 petition, which is limited to reviewing questions of law. The CIAC’s determinations on the allocation of delay, the insufficiency of evidence for defective works, the compliance of Engr. Lumbay, and the awards for counterclaims were based on its assessment of the evidence presented, which the appellate court found to be supported by substantial evidence. Therefore, the assailed CA Decision and Resolution were affirmed.
