JUDICIAL REVIEW OF THE FINDINGS OF THE CIAC and QUASI-JUDICIAL AGENCY
METRO CONSTRUCTION, INC. vs. CHATHAM PROPERTIES, INC. G.R. NO. !"!#$%, S&'(&)*&+ ", !
FACTS/ Respondent, Chatham Properties, Inc. (CHATHAM) and petitioner, Metro Construction, Inc. (MCI) entered into a contract for the construction of the multi-storey uildin! "no#n as the Chatham House. MCI instituted a re$uest for ad%udication of its claims #ith the CIAC to collect from CHATHAM CHATHAM a sum of money for unpaid pro!ress illin!s and other char!es. The CIAC rendered a decision in fa&or of the Claimant (MCI). Impu!nin! the decision of the CIAC, CHATHAM CHATHAM instituted a '&(0(01n 21+ +&v0&3 30(4 (4& C15+( 12 A''&a6s alle!in! that the Aritral Triunal Triunal committed !ra&e error in failin! to consider the e&idences presented y them. C15+( 12 A''&a6s simplified the assi!ned errors into one care issue, namely' the propriety of the CIACs factual findin!s and conclusion. conclusio n. In upholdin! the decision of the CIAC, the CA confirmed the %urisprudential principle that the asent of any sho#in! of aritrariness, the CIACs findin!s as an administrati&e a!ency and $uasi-%udicial a!ency ody should not e only accorded #ith !reat respect ut also e !i&en the stamp of finality. urthermore, the CA ruled in fa&or of the respondent, CHATHAM. CHATHAM. MCI then filed a Motion for Reconsideration ut #as denied for lac" of merit, as #ell as CHATHAMs Motion to *ift +arnishment and *e&y Pendin! Appeal for ein! premature. Thus, MCI filed the instant '&(0(01n 21+ +&v0&3 to challen!e the decision of the Court of Appeals.
ISSUE/ !. hether or not CIAC is a $uasi-%udicial a!ency. . hether or not under the eistin! la#s and rules, the Court of Appeals can also +&v0&3 20nd0n7s 12 (4& 2a8(s 12 (4& C1ns(+58(01n Ind5s(+9 A+*0(+a(01n C1))0ss01n CIAC.
RULING/ . /es, a :5as0-;5d080a6 a7&n89 has een defined as an or!an of !o&ernment other than a court and other than a le!islature, #hich affects the ri!hts of pri&ate parties throu!h either ad%udication or rule-ma"in! and those #ho are &ested #ith $uasi-%udicial po#ers. The CIACs primary function is that of a $uasi-%udicial a!ency, #hich is to ad%udicate claims and0or determine ri!hts in accordance #ith procedures set forth in 1.2. 334. 5. /es, 6ec. -7 of Rule 87 of the 99: Rules of Ci&il Procedure and 6upreme Court Re&ised Administrati&e Circular ;o. -9< oth includes the CIAC in the enumeration of the $uasi-%udicial a!encies comprehended therein. 6ec. 7 of the former states that an appeal under the Rule may e ta"en to the Court of Appeals #ithin the period and in the manner pro&ided there, #hether the appeal in&ol&es $uestion of fact, of la#, or mied $uestions of fact and la# #hile the latter included the CIAC in its enumeration of the $uasi-%udicial a!encies.
