Eterton Multi-Resources v. Filipino Pipe
REITERATIONFacts
The Antecedents: Eterton Multi-Resources Corporation (ETERTON) and Filipino Pipe and Foundry Corporation (FPFC) entered into an Agreement where ETERTON was to deliver asbestos cement pipes for FPFC's Metropolitan Waterworks and Sewerage System PG-8 Project. FPFC paid a substantial amount, but ETERTON only delivered a portion of the pipes. ETERTON then refused to deliver the remaining pipes unless the price was increased. FPFC paid the increased amount under protest to meet project deadlines. Procedural History: FPFC filed a collection suit against ETERTON for the value of undelivered pipes and the return of overpayment. ETERTON denied the allegations, claiming the amounts were for price escalation and penalties. The Regional Trial Court (RTC) ruled in favor of FPFC, ordering ETERTON to pay for excess payments due to short delivery, with interest, and attorney's fees. The Court of Appeals (CA) affirmed the RTC's decision with modification, deleting the award of attorney's fees. ETERTON's motion for reconsideration was denied. The Petition: ETERTON filed a petition for review on certiorari under Rule 45, assailing the CA's decision for sustaining FPFC's claim for excess payment due to short delivery. ETERTON argued that the CA ignored the price escalation schedule and that deliveries were sometimes refused by FPFC, leading to escalated prices upon subsequent acceptance.
Issue(s)
Whether the Court of Appeals erred in sustaining the Regional Trial Court's findings of fact regarding short delivery and excess payment. Whether ETERTON is liable for the value of undelivered asbestos cement pipes.
Ruling
The petition is DENIED. The May 28, 2007 Decision and October 1, 2007 Resolution of the Court of Appeals in CA-G.R. CV No. 66917 are AFFIRMED.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in sustaining the Regional Trial Court's findings of fact regarding short delivery and excess payment: The Supreme Court held that the issue raised by ETERTON pertains to the correctness of factual findings, which is generally beyond the scope of a petition for review on certiorari under Rule 45 of the Rules of Court. The Court emphasized that it is not a trier of facts and does not re-examine or re-weigh the evidence presented by the parties. Both the RTC and the CA concurrently found that there was a short delivery amounting to ₱104,102.67. The RTC meticulously explained its computation, detailing the differences in quantities based on invoices and gate passes, and addressing ETERTON's contentions regarding proof of delivery. The RTC's reasoning for using the invoice unit prices as the basis for computation, despite the price escalation clause, was also clearly laid out, noting ETERTON's own allegations and failure to present crucial evidence like a Debit Memo. The Supreme Court found no compelling reason to depart from these concurrent factual findings, as they were well-supported by the evidence on record and were not reached arbitrarily or capriciously. The Court reiterated that such findings are binding and conclusive on the Supreme Court, absent any showing that the lower courts overlooked, misunderstood, or misappreciated facts that would alter the outcome. On the issue of whether ETERTON is liable for the value of undelivered asbestos cement pipes: The Supreme Court affirmed the findings of the RTC and CA that ETERTON was liable for the value of the undelivered pipes. The concurrent findings established a short delivery of goods worth ₱104,102.67. ETERTON's defense that the amounts were applied to price escalation and penalties was rejected by the CA for lack of sufficient evidence. The RTC's detailed analysis, which considered the discrepancies in quantities and the admitted over-deliveries by FPFC, led to the net award for FPFC. The Supreme Court found no reversible error in the CA's affirmation of the RTC's decision, as the factual determination of short delivery and the resulting liability was adequately substantiated by the evidence presented and evaluated by the lower courts. The Court's role under Rule 45 is limited to reviewing errors of law, not re-evaluating factual determinations that have been consistently made by the trial and appellate courts.
Main Doctrine
The Supreme Court will not disturb the factual findings of the trial court and the Court of Appeals when they are supported by evidence on record, unless there are exceptional circumstances that warrant a review, none of which were present in this case.