This case has been cited 1 times or more.
|
2014-01-15 |
PERLAS-BERNABE, J. |
||||
| The Court concurs with the CA that First Sta. Clara is entitled to be compensated for the development works it had accomplished on the project based on the principle of quantum meruit. Case law instructs that under this principle, a contractor is allowed to recover the reasonable value of the thing or services rendered despite the lack of a written contract, in order to avoid unjust enrichment.[33] Quantum meruit means that, in an action for work and labor, payment shall be made in such amount as the plaintiff reasonably deserves.[34] The measure of recovery should relate to the reasonable value of the services performed[35] because the principle aims to prevent undue enrichment based on the equitable postulate that it is unjust for a person to retain any benefit without paying for it.[36] In this case, it is undisputed that First Sta. Clara already performed certain works on the project with an estimated value of P4,578,152.10. Clearly, to completely deny it payment for the same would result in Rivelisa Realty's unjust enrichment at the former's expense. Besides, as may be gleaned from the parties' correspondence, Rivelisa Realty obligated itself to unconditionally reimburse First Sta. Clara the amount of P3,000,000.00 (representing First Sta. Clara's valuation of its accomplished works at P4,578,152.10, less the cash advances and subcontractor's fees) after the JVA had already been terminated by them through mutual assent. As such, Rivelisa Realty cannot unilaterally renege on its promise by citing First Sta. Clara's non-fulfillment of the terms and conditions of the terminated JVA. For all these reasons, the CA's ruling must be upheld. | |||||