GLOBAL MEDICAL CENTER OF LAGUNA, INC., PETITIONER, VS. ROSS SYSTEMS INTERNATIONAL, INC., RESPONDENT. [G.R. No. 230119, May 11, 2021] ROSS SYSTEMS INTERNATIONAL, INC., PETITIONER, VS. GLOBAL MEDICAL CENTER OF LAGUNA, INC., RESPONDENT.
- G.R. Number: G.R. No. 230112
- Promulgated: 2021-05-11
- Ponente: Caguioa, J.
Doctrine
Factual findings of CIAC arbitral tribunals are final and conclusive; factual review is permissible only under narrow, tribunal-centered exceptions that assail the integrity of the arbitral tribunal, rather than mere disagreements on factual determinations.
A question of law involves doubt as to what the law is on a certain state of facts and is resolved without reviewing evidence; appeals from CIAC arbitral awards raising pure questions of law lie exclusively with the Supreme Court via Rule 45.
Facts
On 10 May 2016, the Construction Industry Arbitration Commission rendered a Final Award in CIAC Case No. 20-2015 concerning a dispute between Global Medical Center of Laguna, Inc. and Ross Systems International, Inc.
The Court of Appeals partially granted the appeal and modified the award, holding that Ross Systems International, Inc. was entitled to P1,088,214.83 after deducting previous payments and creditable withholding taxes.
The Court of Appeals determined that Global Medical Center of Laguna, Inc. had already remitted P3,815,996.50 in creditable withholding taxes on Progress Billings Nos. 1 to 14 to the Bureau of Internal Revenue.
Issues
Whether the direct appeal of CIAC arbitral awards to the Supreme Court on pure questions of law constitutes an increase in appellate jurisdiction requiring the Court's advice and concurrence under Section 30, Article VI of the 1987 Constitution.
Whether appeals challenging findings of law of the CIAC arbitral tribunal are cognizable exclusively by the Supreme Court under Rule 45.
Ruling
No. There was no increase in jurisdiction requiring concurrence because the Supreme Court was already exercising appellate jurisdiction over CIAC awards on pure questions of law under Executive Order No. 1008 prior to the 1987 Constitution.
Yes. If a party seeks to challenge a finding of law of the CIAC arbitral tribunal, the appeal may only be brought before the Supreme Court under Rule 45, without requiring a review of the evidence.
Keywords
Rule 45 Rules of Court, Executive Order No. 1008, Revenue Regulation No. 2-98, Republic Act No. 7902, Republic Act No. 876, Republic Act No. 9285, 1987 Constitution Article VIII Section 5(2)(e), 1987 Constitution Article VIII Section 1, 1987 Constitution Article VI Section 30, Doctrine of Last Clear Chance, Construction Arbitration, Taxation/Creditable Withholding Tax, Judicial Review of Arbitral Awards, Appellate Jurisdiction, Petition for Review on Certiorari, Arbitral Award, Creditable Withholding Tax (CWT), Jurisdiction, Motion for Reconsideration, Questions of Law