- Petitioner
- Leighton Contractors Philippines
- Respondent
- Cnp Industries
- Citation
- G.R. No. 160972
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Corona, J.
- Decided
- March 9, 2010
Summary
Leighton Contractors subcontracted structural steelworks to CNP Industries for a fixed lump-sum price of P44,223,909. When design revisions required additional steel for roof ridge ventilation and crane beams, CNP claimed these were extra works worth P13,442,882. The CIAC and Court of Appeals ruled in CNP's favor, finding the additional works were outside the original contract scope. However, the Supreme Court reversed, holding that the subcontract's main drawings clearly included the disputed works. The Court emphasized that CNP failed to comply with Civil Code Article 1724's strict requirements for additional work claims: written authorization for changes and written agreement on price increases. In fixed lump-sum contracts, contractors assume risks of measurement errors and cost variations, and cannot claim additional payments without proper documentation and authorization.