Professional Documents
Culture Documents
FF Mañacop Const Co Inc Vs CA 122196
FF Mañacop Const Co Inc Vs CA 122196
FF Mañacop Const Co Inc Vs CA 122196
and MIAA
G.R.No. 122196 15January1997
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.”