Title
Henson, Jr. vs. UCPB General Insurance Co., Inc.
Case
G.R. No. 223134
Decision Date
Aug 14, 2019
A water leak damaged insured equipment; UCPB, as subrogee, sued building owner for negligence. Court ruled claim not prescribed, citing 10-year prescriptive period under subrogation law.

Case Digest (G.R. No. 223134)
Expanded Legal Reasoning Model

Facts:

  • Lease and Insurance
    • From 1989 to 1999, National Arts Studio and Color Lab (NASCL) leased the front portion of the ground floor of a two-storey building in Angeles City, Pampanga, owned by Vicente G. Henson, Jr. (Henson).
    • In 1999, NASCL shifted to a different portion of the building and carried out renovations involving the piping assembly. Copylandia Office Systems Corp. (Copylandia) then occupied the ground floor.
  • Water Leak, Damage, Settlement, and Subrogation
    • On May 9, 2006, a water leak in the building damaged Copylandia’s equipment, resulting in P2,062,640.00 in losses. Copylandia’s equipment was insured with UCPB General Insurance Co., Inc. (UCPB Gen).
    • Copylandia filed an indemnity claim and, on November 2, 2006, settled with UCPB Gen for P1,326,342.76, thereby subrogating UCPB Gen to Copylandia’s rights against parties responsible for the damage.
  • Demand, Complaint, Pleadings, and Lower Court Rulings
    • On May 20, 2010, UCPB Gen, as subrogee, made an extrajudicial demand on NASCL and others, then filed a complaint for damages (Civil Case No. 10-885) before the RTC of Makati City after demand was not met.
    • Meanwhile, Henson transferred the building’s title to Citrinne Holdings, Inc. (CHI) in 2010. UCPB Gen amended its complaint on October 6, 2011 to add CHI as defendant. On April 21, 2014, it moved to drop CHI and implead Henson instead, prompting CHI’s opposition on the ground of prescription.
    • In Orders of June 10 and September 22, 2014, the RTC ordered CHI dropped and Henson joined as defendant, holding that UCPB Gen’s subrogation claim arose on indemnification and prescribes in ten years. On November 13, 2015 and February 26, 2016, the Court of Appeals denied Henson’s Rule 65 petition and reconsideration, affirming the RTC.

Issues:

  • Whether UCPB Gen.’s subrogation cause of action against Henson has already prescribed.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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