Republic of the Philippines v. Carlito Lacap

Summary

The Supreme Court ruled that a contractor with an expired license at the time of contract execution is entitled to payment for completed government projects. Carlito Lacap completed a road concreting project for DPWH but was denied payment when COA discovered his contractor's license had expired. Despite DPWH Legal Department opinions in 1993-1994 recommending payment, the government refused to pay. The Court held that exceptions to exhaustion of administrative remedies applied due to unreasonable delay and the purely legal nature of the question. R.A. No. 4566 does not void such contracts but only imposes fines. Applying Civil Code Article 22 on unjust enrichment, the Court ordered payment of the contract price, ruling that the government cannot retain benefits of completed work without compensation. The decision affirms that technical licensing defects cannot defeat valid contractual obligations where performance has been completed and accepted.