Civil Law 2- ObliCon- F.F. Manacop Construction Co. Inc., vs. CA and MIAA

This case is with reference to Art 1160 of the New Civil Code- Quasi- Contracts

Case of FF. MAÑACOP CONSTRUCTION CO., INC. VS. C.A. and MIAA
G.R.No. 122196 15January1997

FACTS OF THE CASE:
Ff Mañacop Construction Company Inc, was contracted by MIAA to construct a perimeter fence from Asia Overseas Inc to Airscope Development Corp. for and in consideration of the quoted price of 307,440.00 Due to the urgency of the need, FFMCC proceeded with the fence construction even if the Notice to Proceed has not yet been signed by the General Manager.
After the Feb 1986 Revolution, the new general manager of MIAA stopped the construction of said fence, by the time of the halt in construction it is already 95% finished which was worth 282,068.00.
After making repeated demands to make MIAA pay for the constructed fence, FMCC filed a case against MIAA. During trial it has been found that MIAA is liable to pay 238,501.48 based upon quantum meruit since there is an absence of a written contract between parties. On appeal the Court agreed with MIAA with regard to the error of the trial court in the valuation of the obligation. According to the decision of the Appellate Court, the computation for the obligation owed by MIAA should be referred to the Commission on Audit, as was shown in the case of Eslao v. Commission on Audit.

ISSUES OF THE CASE:

Was the RTC correct in ordering MIAA to pay FMCC on the basis of Quantum Meuit?

- Yes. The S.C. basing its decision on the Eslao case, it was shown the contract was not fraudulent or mala in se, also it has been shown that the project was already covered by a specific appropriation.
- Property or benefit is not ultra vires (they can be a subject of an express contract and are within the contractual powers of the public body)
- It is shown as well that MIAA was reaping the benefits from the scallop fence and wire placed by the petitioner.
- It is also shown that the payment is limited to the actual cost of chargeable against funds authorized and certified for such purpose.
- Unliquidated claims present a justiciable question ripe for judicial determination which is beyond the powers of COA to adjudicate.

[ The difference between the Eslao case and this one, is that the matter was referred to the COA for the Eslao case because the matter on the exact amount was not at issue and the determination thereof involves a review of the factual findings and evidence in support thereof. For this case the Lower court has already determined the actual amount owed by MIAA to FMCC, so there was no need for referral to COA]

HELD:

The decision of the Court of Appeals is set aside and the decision of the RTC is reinstated.

Obligations and Contracts Terms:

Difference of Quantum Meruit from Quantum Valebant- Quantum Meruit allows recovery of the reasonable value regardless of any agreement as to value. It entitles the party to “as much as he, reasonable deserves”, as distinguished from Quantum Valebant or to “as much as what is reasonably worth.”



I hope this helps.

Jeff David