Credits to the writer

MARIO M. GERONIMO V. COA

G.R. No. 2224163 December 4, 2018
Reyes, J. Jr., J.

Case:

A Petition for Certiorari seeking the reversal of COA Decision No. 2014-311 dated November 10,
2014, which denied the Petition for Money Claim of herein Petitioner, Mario M. Geronimo,
doing under the name and style of Kabukiran Garden against the Department of Public Works
and Highways (DPWH)

Facts:

Petitioner alleged that the DPWH, through the officials and then Secretary Florante Soriquez,
asked him to do several landscaping projects along Ayala Boulevard, Padre Burgos St., Roxas
Boulevard, Osmeña Highway and other major thoroughfares within Metro Manila in connection
with the 112th Inter Parliamentary Union (IPU) Summit in Manila.

The parties involved did not execute any written contract due to time constraint. Upon
completion, Petitioner alleged that he incurred a total amount of ₱14,245,994.20. Despite such
completion and several demands, DPWH failed to pay Petitioner compensation for the services
rendered. Hence, Petitioner filed a Petition for Money claim before the Commission.

He attached in his Petition several letters and memoranda signed by the officials of DPWH, as
well as photographs of the completed projects to support his claims. DPWH, on the other hand,
denied the liability arguing that there was no written contract between him and the
department. It further argued that Petitioner cannot claim compensation based on quantum
meruit as there was no proof that the landscaping projects have been completed in accordance
with the approved plans and specifications by the DPWH, and that the public benefited
therefrom.

The Commission ruled that the principle of quantum meruit is applicable. However, it still
denied the Petition and ruled that the Petition lacks supporting documents that would
substantiate the project accomplishment and the reasonableness of the cost thereof, pursuant
to PD No. 1445 which requires the submission of complete documents in claims against the
government funds.

Issue:

Whether the Commission erred when it denied Petitioner’s claim despite its finding that
DPWH’s liability in favor of Petitioner exists

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Ruling:

The Supreme Court (SC) ruled that the Commission erred when it denied the Petition for Money
Claim. The SC directed the Commission to determine and ascertain with dispatch, on a quantum
meruit basis, the total compensation due to Petitioner.

Principle of quantum meruit is applicable in this case.

Jurisprudence dictates that absence of written contracts would not necessarily

preclude that contractor from receiving payment for the services he or she has rendered
for the government.1 The Court further explained that denial of the contractor’s claim
would result in the government unjustly enriching itself. Justice and equity demand
compensation on the basis of quantum meruit.2 Recovery on the basis of quantum
meruit was also allowed despite invalidity or absence of a written contract between the
contractor and the government agency.3

Liability of DPWH sufficiently established

The Commission’s findings that DPWH acknowledged the existence of its

obligation for the landscaping and beautification project should be treated with utmost
respect. The letters and memoranda presented by the Petitioner unmistakably
established DPWH’s recognition of the completion of the projects and its liability
therefor. These projects obviously redounded to the benefit of the public in the form of
uplifting the image of the country – albeit superficially – to the foreign dignitaries who
passed through these thoroughfares during the IPU Summit. It would be unjust and
inequitable if there is no compensation for the actual work performed and services
rendered by Petitioner.

However, without any reasonable computation and supporting document, such

as receipts of materials procured for the projects, to justify the figures contained
therein, these summaries could only be considered s self-serving statements which the
Commission properly disregarded. According to the SC, the most judicious action that
the Commission should have taken is to require Petitioner to submit additional
supporting evidence and/or employ whatever auditing technique is necessary to
determine the reasonable value of the services he rendered, and the market value of
the materials used in the subject landscaping projects.

1
RG Cabrera Corp., Inc. v. Department of Public Works and Highways. 7977 Phil 563, 569-570 (2016)
2
Dr. Eslao v. Commission on Audit. 273 Phil 97, 107 (1991)
3
Royal Trust Construction v. Commission on Audit. G.R. No. 84202, November 23, 1988.

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/APG
March 12, 2019

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