THE COMMISSION ON AUDIT

MARIO M. GERONIMO V. COA

G.R. No. 2224163

FACTS:

Petitioner alleged that the DPWH, through the officials and then Secretary Florante Soriquez,
asked him to do several landscaping projects along Ayala Boulevard, Padre Burgos St., Roxas
Boulevard, Osmeña Highway and other major thoroughfares within Metro Manila in connection
with the 112th Inter Parliamentary Union (IPU) Summit in Manila.

The parties involved did not execute any written contract due to time constraint. Upon completion,
Petitioner alleged that he incurred a total amount of ₱14,245,994.20. Despite such completion and
several demands, DPWH failed to pay Petitioner compensation for the services rendered. Hence,
Petitioner filed a Petition for Money claim before the Commission.

He attached in his Petition several letters and memoranda signed by the officials of DPWH, as well
as photographs of the completed projects to support his claims. DPWH, on the other hand, denied
the liability arguing that there was no written contract between him and the department. It further
argued that Petitioner cannot claim compensation based on quantum meruit as there was no proof
that the landscaping projects have been completed in accordance with the approved plans and
specifications by the DPWH, and that the public benefited therefrom.

The Commission ruled that the principle of quantum meruit is applicable. However, it still denied
the Petition and ruled that the Petition lacks supporting documents that would substantiate the
project accomplishment and the reasonableness of the cost thereof, pursuant to PD No. 1445 which
requires the submission of complete documents in claims against the government funds.

ISSUE:

Whether or not the Commission erred when it denied Petitioner’s claim despite its finding that
DPWH’s liability in favor of Petitioner exists

RULING:

The Supreme Court (SC) ruled that the Commission erred when it denied the Petition for Money
Claim. The SC directed the Commission to determine and ascertain with dispatch, on a quantum
meruit basis, the total compensation due to Petitioner.

Jurisprudence dictates that absence of written contracts would not necessarily preclude that
contractor from receiving payment for the services he or she has rendered for the government. The
Court further explained that denial of the contractor’s claim would result in the government
unjustly enriching itself. Justice and equity demand compensation on the basis of quantum meruit.
Recovery on the basis of quantum meruit was also allowed despite invalidity or absence of a
written contract between the contractor and the government agency.

The Commission’s findings that DPWH acknowledged the existence of its obligation for the
landscaping and beautification project should be treated with utmost respect. The letters and
memoranda presented by the Petitioner unmistakably established DPWH’s recognition of the
completion of the projects and its liability therefor. These projects obviously redounded to the
benefit of the public in the form of uplifting the image of the country – albeit superficially – to the
foreign dignitaries who passed through these thoroughfares during the IPU Summit. It would be
unjust and inequitable if there is no compensation for the actual work performed and services
rendered by Petitioner.

However, without any reasonable computation and supporting document, such as receipts of
materials procured for the projects, to justify the figures contained therein, these summaries could
only be considered s self-serving statements which the Commission properly disregarded.
According to the SC, the most judicious action that the Commission should have taken is to require
Petitioner to submit additional supporting evidence and/or employ whatever auditing technique is
necessary to determine the reasonable value of the services he rendered, and the market value of
the materials used in the subject landscaping projects.