Petitioner
William Golangco Construction Corporation
Respondent
Philippine Commercial International Bank
Citation
G.R. No. 142830
Court
Supreme Court
Division
Second Division
Ponente
Corona, J.
Decided
March 24, 2006

Summary

This commercial law case involved a construction contract dispute between WGCC and PCIB over liability for defects in granitite wash-out finish that appeared after the contractual one-year defects liability period expired. PCIB accepted the completed PCIB Tower II Extension Project in 1992, but defects appeared in 1993. When WGCC declined to redo the entire work, PCIB hired another contractor at a cost of P11.665 million and sought reimbursement through CIAC arbitration. The Supreme Court reversed lower tribunals, ruling that the one-year defects liability period was valid under the principle of autonomy of contracts (Article 1306, Civil Code). The Court held that defects appearing after the contractual guarantee period cannot make the contractor liable, emphasizing that contracts have the force of law between parties and courts cannot relieve parties from unfavorable but validly entered contracts.

Intellegal Wiki · Key Holding

A contractually stipulated defects-liability period is valid and binding (Article 1306); defects arising after that period do not make the contractor liable, and defects known to a supervising owner are not hidden defects (Article 1719).

An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.

Statutes applied

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By the Intellegal Editorial Board · March 24, 2006

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