Advanced Foundation Construction Systems Corporation v. New World Properties

Summary

This consolidated construction dispute involved AFCSC's claim for payment of extra work and change orders against New World for a P36-million bored pile foundation project. The Supreme Court resolved three key issues: (1) payment for underground obstruction removal, awarding AFCSC full compensation of P8,025,836.37 based on unjust enrichment principles under Civil Code Article 22, rejecting the Court of Appeals' 50% reduction; (2) pile testing costs of P336,683.48 to be borne by New World per construction industry practice; and (3) AFCSC's liability for P1,000,000 liquidated damages due to failure to request time extensions despite circumstances justifying delay. The decision emphasized preventing unjust enrichment while recognizing contractual obligations, ultimately modifying the Court of Appeals ruling to ensure fair compensation for necessary extra work while maintaining consequences for procedural non-compliance.