SPOUSES CHUNG v. ULANDAY CONSTRUCTION, INC. G.R. NO. NO. 1560 156038 38 OCTO OCTOBER BER 11, 11, 2010 2010 Fac!" In Febr ebruar uary y 198 1985, 5, th the e pet petiti ition oners ers con contra tracte cted d wit with h re respo sponde ndent nt Ula Ulanda nday y Construction, Inc. (respondent) to construct, within a 150day period, the concrete structur stru ctural al she shell ll o! the !or !or"er# "er#s s twost twostore orey y res resident idential ial hous house e in Urd Urdanet aneta a $il $illa%e la%e,, &a'ati City at the contract price o! ,*91,1+*.00. he Contract pro-ided that (a) the respon respondent dent shall supply all the necessary "aterials, labor, and e/uip"ent indispensable !or the co"pletion o! the proect, ecep e ceptt !or wor' wor' to be done by oth other er contrac contractor tors2 s2 (b) the pet petiti ition oners ers shall shall pay a 983,+*.40 downpay"ent, with the balance to be paid in pro%ress pay"ents based base d on actu actual al wor' co"pleted2 co"pleted2 (c) the Constructio Construction n &ana &ana%er %er or r rchit chitect ect shall chec ch ec' ' th the e res espo pond nden ent# t#s s re/ e/ue uest st !o !orr pr pro% o%rres ess s pa pay" y"en entt an and d en endo dors rse e it to th the e 11 petitioners !or pay"ent within days !ro" receipt2 (d) the petitioners shall pay the respondents respon dents within 3 days !ro" receipt o! the Constructio Construction n &ana%er#s or rchitec rchitect#s t#s certi6cate2 (e) the respondent cannot chan%e or alter the plans, speci6cations, and wor's without the petitioners# prior written appro-al2 appro-al2 (!) a penalty e/ual to 0.017 o! the contract a"ount shall be i"posed !or each day o! delay in co"pletion, but the respondent shall be %ranted proportionate ti"e etension !or delays caused by the petitione petit ioners2 rs2 (%) the res respond pondent ent sha shall ll cor correc rect, t, at its epe epense, nse, de!e de!ects cts appe appearin arin% % durin% dur in% the 1* 1*"on "onth th war warran ranty ty per period iod a! a!ter ter the pet petiti itione oners rs## iss issuan uance ce o! 6na 6nall acceptance o! wor'. n &arch 13, 1995, the petitioners paid the downpay"ent, with the balance to be paid based on the pro%ress billin%s. s the actual construction went on, the respondent sub"itted 1* pro%ress billin%s. hile the petitioners settled the 6rst 3 pro%ress billin%, pay"ent was "ade beyond the se-en (3)day period pro-ided in the con contra tract ct.. :u :urin rin% % the con constr struct uction ion,, th the e re respo sponde ndent nt als also o e;e e;ecte cted d 19 cha chan% n%e e orders without the petitioners# prior written appro-a. he petitioners, howe-er, paid !or Chan%e rder
real o>ce o! the e/uitable nor" o! estoppel is li"ited to supplyin% de6ciency in the law, but it should not supplant positi-e law. In this case, the re/uire"ent !or the petitioners# written consent to any chan%e or alteration in the speci6cations, plans and wor's is eplicit in rticle 13*+ o! the Ci-il Code and is dee"ed written in the contract between the parties. he contract also epressly pro-ides that a "ere act o! tolerance does not constitute appro-al. hus, the petitioners did not, by acceptin% and payin% !or Chan%e rder
)EGAN SUGAR CORPORATION v. REGIONAL TRIAL COURT G.R. NO. 1*0352 +UNE 1, 2011 Fac!" ?espondent
=CIA 6led a &otion !or :eli-eryB:eposit o! &ill @haresB?entals and such was %ranted. tty. @abi% 6led an "nibus &otion !or ?econsideration and Clari6cation but such was denied. In denyin% &=<#s petition, the C ruled that since tty. @abi% had acti-ely participated be!ore the ?C, &=< was already estopped !ro" assailin% the ?C#s urisdiction.
I!!#$" hether or not &e%an is estopped. R#%&'(" Des. he doctrine o! estoppel is based upon the %rounds o! public policy, !air dealin%, %ood !aith and ustice, and its purpose is to !orbid one to spea' a%ainst his own act, representations, or co""it"ents to the inury o! one to who" they were directed and who reasonably relied thereon. he doctrine o! estoppel sprin%s !ro" e/uitable principles and the e/uities in the case. It is desi%ned to aid the law in the ad"inistration o! ustice where without its aid inustice "i%ht result. It has been applied by this Court where-er and whene-er special circu"stances o! a case so de"and. Aased on the e-ents and circu"stances surroundin% the issuance o! the assailed orders, this Court rules that &=< is estopped !ro" assailin% both the authority o! tty. @abi% and the urisdiction o! the ?C. hile it is true, as clai"ed by &=<, that tty. @abi% said in court that he was only appearin% !or the hearin% o! assi @u%ar#s "otion !or inter-ention and not !or the case itsel!, his subse/uent acts, coupled with &=<#s inaction and ne%li%ence to repudiate his authority, e;ecti-ely bars &=< !ro" assailin% the -alidity o! the ?C proceedin%s under the principle o! estoppel.
