LANDBANK OF THE PHILIPPINES vs. MEGAWORDL CORPORATION

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LAND BANK OF THE PHILIPPINES VS.

MEGAWORLD CORPORATION
G.R. Nos. 193893-94. October 9, 2019.
FIRST DIVISION, BERSAMIN, C.J.

As an exception to the general rule that factual findings of the CIAC is binding on the SC,
questions of fact that require a review of such factual findings may still be raised where the
CA has disagreed with the CIAC's factual findings.

Megaworld filed a claim in the Construction Industry Arbitration Commission (CIAC) against
Landbank for the payment balance for the construction of the latter’s project. Landbank
countersued, alleging that it had performed certain works at its own expense because of
Megaworld’s delay.

The CIAC granted the claims of both parties, which, when offset against each other, showed
a net award in favor of Landbank for around ₱6M. Both parties appealed to the CA which
deleted and reduced certain items in the award in favor of Landbank, resulting in an
increase of the net award in favor of Megaworld to ₱35.8M.

Landbank appealed to the SC, challenging individual components of the revised reward.

Is Landbank’s challenge proper?

YES. Since Landbank challenges individual components of the computation contained in the
revised award, they are raising questions of fact that require the re-evaluation of evidence
presented before the CIAC.

Ordinarily, such challenge is disallowed because the factual findings of the CIAC, especially
when affirmed by the CA, are conclusive upon this Court.

The conclusiveness proceeds from the reality that the CIAC, being the quasi-judicial body
that has jurisdiction over disputes involving construction agreements, whether government
or private contracts, holds the recognized technical expertise on such matters, and should
thus be accorded great respect as to its findings thereon. Moreover, the present recourse is
an appeal by petition for review on certiorari, which is limited to the consideration and
resolution of questions of law.

Nonetheless, the Court may review such factual matters by way of exception to the regular
procedure where the CA has disagreed with the CIAC's factual findings. The need arises to
resolve and settle the disagreement. In this appeal, however, the Court confines its review
to the components thereof that the CA modified on appeal, it being reiterated that the
factual findings of the CIAC affirmed by the CA have become conclusive on this Court.

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