- Petitioner
- The President of the Church of Jesus Christ of Latter Day Saints
- Respondent
- Btl Construction Corporation
- Citation
- G.R. No. 176439
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Perlas-Bernabe, J.
- Decided
- January 15, 2014
Summary
This consolidated case involves construction contract disputes between the Church of Jesus Christ of Latter Day Saints and BTL Construction Corporation over a P12,680,000.00 meetinghouse project in Misamis Oriental. BTL ceased work in August 2001 due to financial difficulties when the project was 98% complete, leading to contract termination and engagement of another contractor. The Supreme Court resolved multiple payment disputes, ruling that COJCOLDS owes BTL P1,612,017.74 as unpaid contract balance (inclusive of 10% retention money), while BTL owes COJCOLDS P1,851,280.00 in liquidated damages for 146-day delay, P526,400.00 for cost overrun, and P300,533.49 for overpayments. The decision importantly clarifies that retention money forms part of the contract price rather than constituting a separate liability, and reinforces Civil Code Article 1724 requirements for written authorization and agreement for additional construction work claims. The case demonstrates the specialized jurisdiction of the Construction Industry Arbitration Commission and the courts' approach to complex construction contract disputes involving multiple financial obligations and performance issues.