- Petitioner
- St. Francis Square Realty Corporation [Formerly Asb Realty Corporation]
- Respondent
- William Golangco Construction Corporation
- Citation
- G.R. No. 197996
- Court
- Supreme Court
- Division
- Third Division
- Decided
- August 11, 2014
Summary
This consolidated case involves a construction contract dispute between William Golangco Construction Corporation (WGCC) and St. Francis Square Realty Corporation (formerly ASB Realty Corporation) regarding a 50-storey tower project in Pasig City. The original P316.4 million contract was reduced to P261 million after amendments. When ASBRC delayed payments, WGCC suspended work in 2000. ASBRC subsequently entered SEC rehabilitation proceedings. The dispute involved claims for unpaid billings, extended overhead expenses, and various damages. The Supreme Court upheld the Court of Appeals' decision awarding WGCC P428,682.40 for unpaid progress billings, P2,026,826.18 for extended overhead expenses, and P1,000,000.00 in temperate damages under Civil Code Article 2224, recognizing that while specific losses couldn't be proven with certainty, WGCC clearly suffered pecuniary loss from maintaining excess equipment due to the reduced project scope. The case demonstrates the application of temperate damages in construction disputes and the deference given to administrative agency findings.