Case Digest (G.R. No. 72085) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 228 Phil. 564 (G.R. Nos. L-47851, L-47863 & L-47896; October 3, 1986), the Philippine Bar Association (PBA) contracted United Construction Company, Inc. (UCCI), under the direction of its president Juan J. Carlos, to erect an office building on its Intramuros lot, with Juan F. Nakpil & Sons as architects. Completed in June 1966, the structure suffered major damage during the August 2, 1968 earthquake when its front columns buckled, prompting shoring works costing ₱13,661.28. On November 29, 1968, PBA sued UCCI and Carlos for defective construction, while they impleaded Nakpil & Sons and Nakpil personally via third-party complaint. The trial court referred technical questions to a Commissioner and, after extensive hearings and two subsequent tremors in April 1970, ordered demolition. On September 21, 1971, it awarded PBA ₱989,335.68 plus six months’ rental loss. The Court of Appeals on November 28, 1977 affirmed the lower court but added ₱200,000 for quake-caused damage and co Case Digest (G.R. No. 72085) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Contract
- Philippine Bar Association (PBA), owner; United Construction Co., Inc. (UCCI), contractor; Juan J. Carlos, UCCI’s president and general manager; Juan F. Nakpil & Sons and Juan F. Nakpil, architects; Roman Ozaeta, PBA president.
- PBA engaged UCCI to build its office on an 840 sqm Intramuros lot; plans and specifications by Nakpil & Sons; “administration” basis contract approved by Ozaeta.
- Construction, Damage, and Procedural History
- Building completed June 1966; August 2, 1968 earthquake caused major structural damage—buckled columns, tilting. UCCI shored building (P13,661.28).
- November 29, 1968: PBA sues UCCI and Carlos for defects and contractual violations; UCCI files third-party complaint vs. Nakpil & Sons and Nakpil. Ozaeta joined as third-party defendant.
- March 3, 1969 stipulation: if UCCI/Carlos exonerated, court may hold architects liable as if amended complaint named them.
- Court refers technical issues (cause, design adequacy, repair cost) to Commissioner Andres O. Hizon; non-technical issues tried by trial court. Subsequent strong tremors (April 1970) lead to authorized demolition.
- Commissioner’s September 25, 1970 report: earthquake directly caused damage, but defects in design, deviations by UCCI, poor workmanship, and lack of supervision also proximate causes. Trial court (Sept. 21, 1971) and Court of Appeals (Nov. 28, 1977) affirmed findings, CA added P200,000 damages for April 1970 quake.
- Consolidated Supreme Court petitions by UCCI, Nakpil & Sons, Nakpil (seeking exoneration) and PBA (seeking P1.83 M, exemplary damages, attorney’s fees). Amicus curiae United Architects of the Philippines, Association of Civil Engineers, Philippine Institute of Architects intervene.
Issues:
- Liability for Collapse
- Whether the August 2, 1968 earthquake (act of God) exempts UCCI or architects from liability despite proven design and construction defects.
- Measure of Damages
- Proper amount to award PBA for repair costs, loss of rentals, subsequent quake damage, demolition, and attorney’s fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)