Short answer. Yes, but only on those two grounds. Where a construction contract makes a third person's approval of the work final, that decision stands and cannot be reopened, except in case of fraud or manifest error — an ordinary disagreement with the inspector's judgment is not enough to challenge it.

What the law says

If the work is subject to the approval of a third person, his decision shall be final, except in case of fraud or manifest error.

Civil Code, Article 1730 — Work Done To Satisfaction. Read the full provision →

Two ways a work-acceptance dispute can be resolved

When a construction or piece-of-work contract says the work must be accomplished to the satisfaction of the proprietor, a disagreement over whether it was properly done is not left to the proprietor's say-so alone — it is understood that, in case of disagreement, the question is subject to expert judgment. Separately, the parties may instead agree that the work is subject to the approval of a named third person, rather than expert judgment generally, and that arrangement is treated differently once it is in place. The two mechanisms do not stack: expert judgment is the default reading of a satisfaction clause, while the third-person route applies only because the parties chose to write it into the contract.

Why the third person's decision is normally final

Where the contract routes approval through a third person, that person's decision is final. The point of naming a third-party approver is to give both sides a decision-maker whose call settles the matter, rather than leaving room for either party to keep contesting whether the work was acceptable. Treating the decision as final is what makes the arrangement useful in the first place — an approval that either side could freely relitigate would defeat the purpose of appointing someone to decide. The finality also binds both sides equally — the proprietor is as bound by an approval as the contractor is by a rejection.

The two grounds that can still reopen it

That finality is not absolute. The decision can still be challenged in case of fraud or manifest error — meaning the approval was obtained through dishonesty or collusion, or the mistake in it is obvious rather than a matter of debatable judgment. Because the exception is narrow, a party who simply disagrees with how the third person evaluated the work, without pointing to fraud or an error that is manifest on its face, does not have grounds under this provision to reopen an approval that was otherwise properly given. Whoever alleges fraud or manifest error also carries the burden of showing it; the provision presumes the decision final, so the exception has to be proved, not merely invoked.

Related provisions

Note. Statute text quoted on this page is reproduced from the official enactment and is linked to the full provision. The explanation around it is general legal information from Vivas & Nobles Law Office, not legal advice. Whether it applies to your situation depends on facts only a lawyer reviewing them can assess.