The Supreme Court has ruled that the doctrine of “quantum meruit” (as much as one has deserved) does not apply to private firms that failed to seasonably challenge the notices of disallowance (NDs) issued by the Commission on Audit (COA) in the payments of their government contracts.
In a decision issued last August 22, 2023, the SC dismissed the petition filed by Topbest Printing Corporation assailing the ruling handed down by COA. The copy of the decision written by Justice Maria Filomena D. Singh has not been made public.
The SC stressed that Topbest Printing should not benefit from the doctrine of “quantum meruit,” saying “this principle should not apply in instances where the COA decision sought to be assailed has already attained finality.”
Quoting from the SC Public Information Office stressed that “the rule is settled that when a judgment becomes final and executory, it becomes immutable and unalterable.”
“The petitioner (Topbest Printing), which patently failed to comply with the rules providing the period within which a COA decision may be challenged, and thus allowed the COA decision to attain finality, must suffer the consequences of its lapses,” the high court said.
“By denying the petition and highlighting the importance of the doctrine of immutability of judgments, the Supreme Court emphasized that this doctrine is a fundamental element of our judicial system and must be recognized and applied, save for a narrow set of exceptions,” the SC said in a statement.
“Moreover, the judgment of the Supreme Court in Topbest also underscores that a doctrine as essential as the immutability of judgments cannot be set aside especially where doing so would result in tolerating illegal practices, as in this case where it was found that Topbest engaged in prohibited sub-contracting. The law should not grant leniency to parties who violate fundamental procedural rules and adjective law,” the SC pointed out.
The SC statement, however, did not include in its summary the details of Topbest Printing’s contract with the government. Also, details on how much Topbest Printing was collecting and how much was disallowed by COA were also not included in the summary.