G.R. No. 160867 - Nakpil vs. Manila Towers Development Corp.

A 14-storey high-rise building located at 777 Ongpin St., Sta. Cruz, Manila, owned by Cheong Kiao Ang, was leased in 1964 to about 200 Filipino-Chinese tenants for residential and commercial purposes.
One tenant was Atty. Bonifacio Nakpil who leased Room 204 in the mezzanine floor and used it as his law office.
The tenants organized themselves into the House International Building Tenants Association, Inc. (HIBTAI).
The property was mortgaged with the Government Service Insurance System (GSIS). Upon Cheong Kiao Ang's failure to pay the loan, GSIS foreclosed the mortgage, bought the property at a public auction, and sold it to Centertown Marketing Corporation (CMC), which assigned the rights to Manila Towers Development Corporation (MTDC) for P21 million.
HIBTAI protested, asserting tenants’ priority rights to purchase under Presidential Decree No. 1517.

Tenants ceased paying rent to MTDC, instead remitting to HIBTAI.
In 1981, the City Engineer issued letters to MTDC insisting on correction of building defects which were deemed dangerous.
Despite warnings, MTDC did not effect repairs due to tenants’ legal actions preventing it from taking possession and making repairs.
Several suits were filed by HIBTAI against GSIS, CMC, and MTDC, claiming priority to purchase and seeking annulment of sale contracts; these were dismissed by courts including the Supreme Court in 1987.
MTDC requested an ocular inspection in 1995 through Atty. Samuel Samuela; the City Building Official conducted inspection and found serious structural, electrical, sanitary, architectural defects, and illegal constructions, recommending repairs and tenant vacation.

The City Building Official issued letters to MTDC ordering repairs and evacuation of tenants, warning of administrative sanctions and possible legal action upon non-compliance.
MTDC did not respond; subsequently, a Closure Order was issued in January 1996 ordering evacuation and repair, requiring permits and structural certifications.
Reinspection in March 1996 recommended the City Engineer be authorized to make repairs and to evict occupants for their safety.
The City Mayor approved the recommendation to repair the building at MTDC’s expense and issued notices to tenants to vacate in June 1996.

On July 19, 1996, a group led by Engr. Melvin Balagot, Chief of Slum Clearance and Demolition Services, with policemen, entered the building to start repairs, tearing down some structures; works stopped after a TRO issued in favor of tenant Felix Ong suspending repairs.
Tenants, including Atty. Nakpil (then abroad for medical treatment), claimed illegal demolition and damage; Nakpil’s law office was destroyed, personal belongings lost or stolen.
Nakpil filed Civil Case No. 65980 seeking actual, moral, exemplary damages, attorneys’ fees, and other reliefs against MTDC.
Trial court dismissed complaint; CA reversed in 2003, awarding Nakpil nominal damages of P50,000.
MTDC and Nakpil each filed separate petitions for review before the Supreme Court.

Whether MTDC is liable to Atty. Nakpil for actual, moral, and exemplary damages due to the demolition and loss of possession of the leased premises.
Whether the award of P50,000 nominal damages by the Court of Appeals has factual and legal basis.