G.R. No. L-36627 October 20, 1977
SEVERO J. SANTIAGO, petitioner-appellant, vs. EUGENIO JUAN GONZALEZ, ET. AL., respondents-appellees.

FACTS

Petitioner Severo J. Santiago and respondent Eugenio Juan Gonzalez entered into a construction contract for a residential house. A dispute arose when Gonzalez, alleging delayed payments, stopped construction. To resolve the controversy, the parties executed an arbitration agreement on December 28, 1963, constituting a three-member Arbitration Board. The agreement stipulated that the Board must render its award within thirty days from its constitution and that any motion for reconsideration of the award must be decided by the Board within ten days.
The Arbitration Board rendered its award on July 6, 1964, directing Santiago to pay Gonzalez a balance. Santiago received a copy on August 10, 1964, and promptly filed a motion for reconsideration with the Board on August 24. The Board, however, failed to act on this motion. Subsequently, Santiago filed a petition with the Court of First Instance to vacate the award, while Gonzalez filed a motion for its confirmation. The trial court, after reviewing the records of the arbitration proceedings, confirmed the award and rendered judgment in favor of Gonzalez.

ISSUE

Whether the trial court acted correctly in confirming the arbitration award without conducting a full trial or receiving additional evidence.

RULING

Yes, the trial court acted correctly. The Supreme Court affirmed the decision, emphasizing the limited scope of judicial review over arbitration awards under Republic Act No. 876, The Arbitration Law. The Court found that the Arbitration Board was duly constituted pursuant to the parties’ agreement and that it conducted its proceedings within the scope of its authority. The Board afforded both parties ample opportunity to present their evidence, including through written submissions, ocular inspections, and conferences. The appellant’s claim of being deprived of due process was therefore without merit.
The Court ruled that the trial court was not required to conduct a trial de novo or receive new evidence. Its role was confined to examining whether the award was rendered in accordance with the arbitration agreement and the governing law. The record showed the Board considered Santiago’s numerous claims and explanations. Furthermore, the Court noted that Santiago’s own letter effectively rescinded the construction contract, making the arbitration the agreed mechanism for liquidating their equities. The arbitration award, having been rendered by the board in the exercise of its discretionary powers as granted by the submission agreement, and absent any showing of gross misconduct, fraud, or excess of authority, was properly confirmed by the lower court. The appeal, raising questions factual in nature, was dismissed.