- Petitioner
- Sm Land
- Respondent
- Bases Conversion
- Citation
- G.R. No. 203655
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Velasco, Jr., J.
- Decided
- March 18, 2015
Summary
This case involves a contract dispute between SM Land, Inc. (SMLI) and the Bases Conversion and Development Authority (BCDA) regarding an unsolicited proposal for property development. SMLI submitted a proposal in 2009, which after negotiations led to a Certification of Successful Negotiations in 2010 agreeing to subject the proposal to competitive challenge. BCDA later unilaterally cancelled this process claiming straight bidding would be better. The Supreme Court ruled that a valid contract exists between the parties and that NEDA JV Guidelines have the force of law, preventing BCDA from arbitrarily cancelling the competitive challenge process. The Court applied estoppel against the government and emphasized that SMLI's proposal serves as a floor price, making alleged losses speculative. The decision demonstrates the binding nature of government commitments in procurement processes and the enforceability of administrative guidelines as law.