SC: Quantum meruit not applicable if claimant fails to appeal

The Supreme Court ruled that the principle of quantum meruit could not benefit a claimant who entered into an illegal government contract if they failed to appeal a Commission on Audit (COA) disallowance within the proper time.

In dismissing the petition of a printing company, the Court said the doctrine established in a previous ruling — which states that civil liability for amounts disallowed by COA may be reduced by the amounts due to the recipient based on the principle of quantum meruit — should not apply once the decision being assailed has attained finality.

Quantum meruit is an equitable remedy that provides restitution for unjust enrichment.

“The rule is settled that when a judgment becomes final and executory, it becomes immutable and unalterable,” the SC PIO said in a press release.

“The petitioner, 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,” it added.

Further, the Court said that the doctrine of immutability of judgments, which states that final and executory judgments can no longer be altered or amended, must be recognized and applied “save for a narrow set of exceptions."

“Moreover, the judgment of the Supreme Court... 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,” it said.

“The law should not grant leniency to parties who violate fundamental procedural rules and adjective law,” it added. — DVM, GMA Integrated News