Aguila v. Perfect Dimension Corporation
REITERATIONFacts
The Antecedents: Comglasco Aguila Glass Corporation (Comglasco) contracted Perfect Dimension Corporation (PDC) for architectural, plumbing, sanitary, and electrical works on a unit in Discovery Primea, Makati City, for PHP 7,880,000.00, with a 150-day completion period from downpayment made on July 31, 2014, setting a deadline of December 29, 2014. Work commenced late on November 3, 2014, due to clearance delays, and remained incomplete by the deadline. Comglasco terminated PDC in December 2015 for inefficiency and incomplete work, hiring another contractor. Despite attempts at resolution regarding PDC's performance and Comglasco's incurred costs, no agreement was reached, leading Comglasco to file a complaint with the Construction Industry Arbitration Commission (CIAC) seeking PHP 21,234,076.28 in damages. Procedural History: PDC and Engr. Ronaldo S. Guevarra contended that Comglasco also contributed to delays and approved plans, while Engr. Lumbay asserted he fulfilled his project management duties. The CIAC, in a June 22, 2017 Final Award, found a total delay of 373 days, apportioning responsibility to both parties, with PDC/Engr. Guevarra liable for 76.33 days of delay after accounting for change orders and owner-supplied material delays. The CIAC found insufficient evidence of defective works and that Engr. Lumbay complied with his obligations, partially granting liquidated damages to Comglasco, denying claims for actual damages and unrealized profits, but awarding moral damages and attorney's fees to PDC/Engr. Guevarra, and granting counterclaims for unpaid billings and attorney's fees to PDC/Engr. Guevarra and Engr. Lumbay. Comglasco et al. appealed to the Court of Appeals (CA). The CA, in a July 31, 2018 Decision, affirmed the CIAC award with modifications, finding PDC et al. liable for 133 days of delay and awarding PHP 788,000.00 in liquidated damages, awarding PHP 3,000,000.00 in temperate damages based on certifications of defective works, while denying other claims. The CA also awarded attorney's fees to Comglasco et al. and modified counterclaims. Both parties' motions for reconsideration were denied by the CA in a November 12, 2018 Resolution. The Petition: Petitioners Florante G. Aguila, Comglasco Aguila Glass Corporation, and Valiente Select Venture, Inc. filed a Petition for Review on Certiorari under Rule 45, arguing a 373-day delay by respondents, no approved contract extensions, and that respondents were liable for inefficiency and poor workmanship, thus not entitled to unpaid billings or attorney's fees. Petitioners sought indemnification for unrealized profits, actual, and moral damages, asserting payment certifications and expense lists as sufficient evidence. The Supreme Court, however, determined that the issues raised were primarily questions of fact, generally outside the scope of a Rule 45 petition. Furthermore, the Court noted that a similar petition by PDC and Engr. Guevarra (G.R. No. 243145) assailing the same CA decision had already been denied with finality due to procedural infirmities and failure to show reversible error, constituting res judicata. Consequently, the Court denied the petition.
Issue(s)
Whether the issues raised by petitioners regarding contract extensions, liability for delays, and the weight of payment certifications are questions of fact prohibited in a Rule 45 petition. Whether the principle of res judicata, in the concept of bar by prior judgment, applies to the present case given the finality of G.R. No. 243145. Whether the doctrine of immutability of judgment precludes the Supreme Court from reviewing the factual findings of the Court of Appeals that were already the subject of a final minute resolution.
Ruling
The Petition for Review on Certiorari is DENIED. The July 31, 2018 Decision and the November 12, 2018 Resolution of the Court of Appeals in CA-G.R. SP No. 151582, are AFFIRMED.
Ratio Decidendi
On Issue 1: The Supreme Court emphasized that its jurisdiction under Rule 45 is generally limited to errors of law, as it is not a trier of facts. A question of fact exists when there is doubt as to the truth or falsehood of alleged facts, requiring the re-examination of evidence. The resolution of issues concerning contract extensions, the exact number of days of delay, and the probative value of payment certifications involves a factual re-evaluation. Such matters are beyond the province of a Rule 45 petition unless specific exceptions are proven, which petitioners failed to do. Consequently, the Court found the petition procedurally infirm for raising purely factual disputes already passed upon by lower tribunals. On Issue 2: The Court ruled that res judicata in the concept of 'bar by prior judgment' had set in because G.R. No. 243145 involved identity of parties, subject matter, and causes of action. The minute resolution in G.R. No. 243145, which denied the respondents' earlier petition, constituted an actual adjudication on the merits. Although a minute resolution is compact, it effectively affirms the challenged decision of the Court of Appeals between the same parties. Since the cause of action in both cases was the breach of the same Letter of Award and involved the same project, the previous final judgment serves as an absolute bar to the current suit. The Court noted that the stability of judicial decisions requires that controversies once decided on the merits remain in repose. On Issue 3: The doctrine of finality and immutability of judgment dictates that once a decision attains finality, it becomes unalterable even to correct errors of fact or law. The Court explained that upon the finality of G.R. No. 243145 and the issuance of an Entry of Judgment, the Court lost jurisdiction to amend or modify the findings related to that dispute. The petitioners had an opportunity to consolidate their petition with G.R. No. 243145 but failed to do so, leaving the Court with a final and immutable judgment to uphold. Because the current petition does not fall under exceptions such as clerical error or void judgment, the Court must respect the finality of the prior resolution. Therefore, the Court is precluded from delving into the merits of the petitioners' claims to ensure litigation comes to an end.
Main Doctrine
The primary legal doctrine established and applied in this case is the principle of res judicata, specifically "bar by prior judgment," as it pertains to the binding nature of Supreme Court minute resolutions. The Court clarified that a minute resolution, despite its brevity, constitutes an actual adjudication on the merits when it dismisses a petition for failing to meet formal or substantive requirements, or for lacking reversible error. This means that such a resolution can serve as a final judgment, conclusively settling the rights of the parties and barring any subsequent action involving the same parties, subject matter, and causes of action, thereby upholding the stability and finality of judicial pronouncements in Philippine jurisprudence.