GR L 15198; (May, 1960) (Digest)
G.R. No. L-15198; May 30, 1960
EDUARDO J. JALANDONI, plaintiff-appellant, vs. NATIONAL RESETTLEMENT and REHABILITATION ADMINISTRATION, ET AL., defendants-appellees.
FACTS
The National Resettlement and Rehabilitation Administration (NARRA) held a public bidding for plowing and harrowing projects in several locations. Jaro Machineries and Engineering Co., represented by its proprietor Eduardo J. Jalandoni, submitted bids for the Maramag, Bukidnon project and the Tabugon and Cabanbanan, Negros Occidental project. The bidding conditions included a reservation of NARRA’s right to reject any or all bids. The Committee on Bids found Jaro Machineries to be the sole bidder for Tabugon and Cabanbanan and the lowest bidder for Maramag. However, the NARRA Board of Directors rejected all bids, deeming the prices too high, and decided to have the work undertaken by NARRA itself. Jalandoni protested to the President of the Philippines, who denied the protest. Jalandoni then filed a complaint for damages with mandatory and prohibitory injunction against NARRA and its Board members, seeking unrealized profits and to compel the signing of a contract. The defendants moved to dismiss the complaint for lack of cause of action, arguing that by participating in the bidding, plaintiff subjected himself to NARRA’s right to reject all bids. The Court of First Instance of Manila dismissed the complaint.
ISSUE
Whether the lower court correctly dismissed the complaint for lack of cause of action.
RULING
Yes, the lower court correctly dismissed the complaint. By participating in the public bidding, the plaintiff-appellant submitted to NARRA’s conditions, including its reserved right to reject any or all bids. The discretion of the authorized body to reject bids is wide, and courts will not interfere unless a fraudulent award is apparent. No such fraud was shown; the rejection was based on the unreasonableness of prices and a decision for economy. The plaintiff’s status as the lowest bidder did not create a vested right to a contract. Since all bids were rejected, there was no meeting of the minds and no perfected contract between the parties. The facts establishing these points were evident from the complaint and its annexes, and a hearing would not have materially changed them. The order of dismissal is affirmed.