Tuesday, May 26, 2009

BENGUET V. CABILDO (REMEDIAL, CIVIL)


It is a well-entrenched doctrine that factual findings of the trial court, especially when affirmed by the appellate court, are accorded the highest degree of respect and are conclusive between the parties and even the courts. Nonetheless, jurisprudence recognizes highly meritorious exceptions such as:

  1. when the findings of a trial court are grounded entirely on speculations, surmises, or conjectures;
  2. when a lower court's inference from its factual findings is manifestly mistaken, absurd, or impossible;
  3. when there is grave abuse of discretion in the appreciation of facts;
  4. when the findings of the appellate court go beyond the issues of the case or fail to notice relevant facts which, if properly considered, will justify a different conclusion;
  5. when there is a misappreciation of facts; and
  6. when the findings of facts are conclusions without mention of the specific evidence on which they are based, are premised, on the absence of evidence, or are contradicted by evidence on record.

It is noteworthy that none of these exceptions which would warrant a reversal of the assailed decision obtains herein.

The SC rejects petitioners' contention that there is an apparent conflict between the wording of the contract and the actual intention of the parties on the specific object of the painting job.

Article 1370 of the Civil Code provides: If the terms of a contract are clear and leave no doubt upon the intention of the contracting parties, the literal meaning of its stipulations shall control.

If the words appear to be contrary to the evident intention of the parties, the latter shall prevail over the former.

The cardinal rule in the interpretation of contracts embodied in the above rule is akin to the Plain Meaning Rule applied by Pennsylvania courts, which assumes that the intent of the parties to an instrument is embodied in the writing itself, and when the words are clear and unambiguous, the intent is to be discovered only from the express language of the agreement.

It also resembles the Four Corners Rule, a principle which allows courts in some cases to search beneath the semantic surface for clues to meaning. A court's purpose in examining a contract is to interpret the intent of the contracting parties, as objectively manifested by them. The process of interpreting a contract requires the court to make a preliminary inquiry as to whether the contract before it is ambiguous.

A contract provision is ambiguous if it is susceptible of two reasonable alternative interpretations. Where the written terms of the contract are not ambiguous and can only be read one way, the court will interpret the contract as a matter of law. If the contract is determined to be ambiguous, then the interpretation of the contract is left to the court, to resolve the ambiguity in the light of the intrinsic evidence.

In the case at bench. the Contract of Work leaves no room for equivocation or interpretation as to the exact intention of the parties. We also note that Benguet's counsel drafted and prepared the contract. Undoubtedly, petitioners' claimed ambiguity cannot give rise to an interpretation favorable to Benguet.

Article 1377 of the Civil Code provides: The interpretation of obscure words or stipulations in a co tract shall not favor the party who caused the ambiguity.

It is crystal clear that petitioners breached the Contract of Work with Cabildo by awarding Velasco a contract covering the same subject matter, quite understandably, because Velasco offered a price schedule lower than Cabildo's. We completely agree with the uniform findings of the lower courts that the petitioners waylaid Cabildo and prevented him from performing his obligation under the Contract of Work.



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