ALTERNATIVE DISPUTE RESOLUTION | METRO BOTTLED WATER CORPORATION VS. ANDRADA CONSTRUCTION & DEVELOPMENT CORPORATION, INC., G.R. NO. 202430, MARCH 6, 2019

METRO BOTTLED WATER CORPORATION VS. ANDRADA CONSTRUCTION & DEVELOPMENT CORPORATION, INC., G.R. NO. 202430, MARCH 6, 2019

 

TOPIC/DOCTRINE

The general rule is that appeals of arbitral awards by the Construction Industry Arbitration Commission (CIAC) may only be allowed on pure questions of law.

 

FACTS

For this Court’s resolution is a Petition for Review on Certiorari7 assailing the March 21, 2012 Decision8 and June 25, 2012 Resolution9 of the Court of Appeals, which upheld the April 11, 2002 Arbitral Award of the Construction Industry Arbitration Commission. The arbitral tribunal had ordered Metro Bottled Water Corporation (Metro Bottled Water) to pay Andrada Construction & Development Corporation, Inc. (Andrada Construction) the amount of P4,607,523.40 with legal interest from November 24, 2000 as unpaid work accomplishment in the construction of its manufacturing plant.

 

ISSUE

Whether petitioner raises a question of law that is appealable to the Court of Appeals.

 

RULING

No.

The court ruled that the general rule is that appeals of arbitral awards by the Construction Industry Arbitration Commission (CIAC) may only be allowed on pure questions of law. Spouses David v. Construction Industry and Arbitration Commission, 435 SCRA 654 (2004), recognized this gap, and thus, applied the provisions of Republic Act No. 876, or the Arbitration Law: [F]actual findings of construction arbitrators are final and conclusive and not reviewable by this Court on appeal, except when the petitioner proves affirmatively that: (1) the award was procured by corruption, fraud or other undue means; (2) there was evident partiality or corruption of the arbitrators or of any of them; (3) the arbitrators were guilty of misconduct in refusing to postpone the hearing upon sufficient cause shown, or in refusing to hear evidence pertinent and material to the controversy; (4) one or more of the arbitrators were disqualified to act as such under section nine of Republic Act No. 876 and willfully refrained from disclosing such disqualifications or of any other misbehavior by which the rights of any party have been materially prejudiced; or (5) the arbitrators exceeded their powers, or so imperfectly executed them, that a mutual, final and definite award upon the subject matter submitted to them was not made.

Here, the court ruled that petitioner raised issues that are questions of fact in the guise of questions of law. As such, they are not proper for this Court’s review. The difference between a question of law and a question of fact is settled. In Spouses David:

There is a question of law when the doubt or difference in a given case arises as to what the law is on a certain set of facts, and there is a question of fact when the doubt arises as to the truth or falsity of the alleged facts. Thus, for a question to be one of law, it must not involve an examination of the probative value of the evidence presented by the parties and there must be no doubt as to the veracity or falsehood of the facts alleged.







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