JUDICIAL REVIEW OF THE FINDINGS OF THE CIAC and QUASI-JUDICIAL

AGENCY

METRO CONSTRUCTION, INC. vs. CHATHAM PROPERTIES, INC.

(G.R. NO. 141897, September 24, 2001)

FACTS:

Respondent, Chatham Properties, Inc. (CHATHAM) and petitioner, Metro

Construction, Inc. (MCI) entered into a contract for the construction of the
multi-storey building known as the Chatham House.
MCI instituted a request for adjudication of its claims with the CIAC to collect
from CHATHAM a sum of money for unpaid progress billings and other
charges.
The CIAC rendered a decision in favor of the Claimant (MCI).
Impugning the decision of the CIAC, CHATHAM instituted a petition for
review with the Court of Appeals alleging that the Arbitral Tribunal
committed grave error in failing to consider the evidences presented by
them.
Court of Appeals simplified the assigned errors into one care issue, namely;
the propriety of the CIACs factual findings and conclusion. In upholding the
decision of the CIAC, the CA confirmed the jurisprudential principle that the
absent of any showing of arbitrariness, the CIACs findings as an
administrative agency and quasi-judicial agency body should not be only
accorded with great respect but also be given the stamp of finality.
Furthermore, the CA ruled in favor of the respondent, CHATHAM.
MCI then filed a Motion for Reconsideration but was denied for lack of merit,
as well as CHATHAMs Motion to Lift Garnishment and Levy Pending Appeal
for being premature.
Thus, MCI filed the instant petition for review to challenge the decision of
the Court of Appeals.

ISSUE:
1. Whether or not CIAC is a quasi-judicial agency.
2. Whether or not under the existing laws and rules, the Court of Appeals
can also review findings of the facts of the Construction Industry
Arbitration Commission (CIAC).

RULING:
1. Yes, a quasi-judicial agency has been defined as an organ of
government other than a court and other than a legislature, which affects
the rights of private parties through either adjudication or rule-making
and those who are vested with quasi-judicial powers. The CIACs primary
function is that of a quasi-judicial agency, which is to adjudicate claims
and/or determine rights in accordance with procedures set forth in E.O.
1008.
2. Yes, Sec. 1-3 of Rule 43 of the 1997 Rules of Civil Procedure and Supreme
Court Revised Administrative Circular No. 1-95 both includes the CIAC in
the enumeration of the quasi-judicial agencies comprehended therein.
Sec. 3 of the former states that an appeal under the Rule may be taken to
the Court of Appeals within the period and in the manner provided there,
whether the appeal involves question of fact, of law, or mixed questions of
fact and law while the latter included the CIAC in its enumeration of the
quasi-judicial agencies.