G.R. No. 94571 - Guingona, Jr. vs. Carague

Case Digest (G.R. No. 94571)
Expanded Legal Reasoning Model

Facts:

Parties and Background

The case involves petitioners—Jose D. Ontimare, Jr. and Rene D. Ontimare, as sons/heirs substituted for their deceased father, Jose M. Ontimare, Sr.—and respondents, the spouses Renato and Rosario Elep.
The dispute arises from a construction controversy between neighboring property owners in Hyacinth Street, Roxas District, Quezon City.

The Construction Dispute and Initiation of Controversy

Respondents, owners of the lot at No. 74 Hyacinth Street, sought to build a four-door, two-storey apartment and applied for a building permit in December 1995.
Ontimare Sr., owner of the adjoining property at No. 72 Hyacinth Street whose terrace abutted the boundary, was affected by the intended construction.
On December 3, 1995, respondents sent Ontimare Sr. a letter seeking written consent for the construction of a firewall adjacent to his existing one.
Rather than consenting, Ontimare Sr. opposed the construction, filing a complaint with the Building Official on December 20, 1995, alleging that the proposed firewall would negatively impact the ventilation and market value of his property.

Administrative and Legal Proceedings Preceding the Trial

Despite the complaint, respondents were initially issued a building permit on January 8, 1996.
In response to Ontimare Sr.’s request, a Cease and Desist Order was issued on January 12, 1996, halting the construction of the apartment.
After respondents clarified that their intended firewall lay entirely within their property, the Cease and Desist Order was lifted on January 16, 1996.
Ontimare Sr.’s complaint was eventually dismissed on January 26, 1996, though he subsequently filed additional administrative actions including an appeal to the City Mayor and a Notarial Prohibition on February 2, 1996.
Following hearings on June 18 and 25, 1996, the Building Official dismissed the complaint on July 11, 1996, while also ordering the petitioner to make adjustments to his house construction.
A new building permit was issued to respondents on July 16, 1996.

The Shotgun Incident and Its Aftermath

On July 15, 1996—one day before the new permit was issued—while respondents’ workers were engaged in plastering and waterproofing work on the firewall, Ontimare Sr. fired his shotgun and threatened to kill anyone who entered his property.
This incident led to part of the firewall being left unfinished, resulting in water seepage that damaged the building’s wood parquet floors, wall paintings, and ceiling.
Respondents subsequently initiated an action for damages with an application for a preliminary injunction and a restraining order against Ontimare Sr.

Trial Court and Court of Appeals Decisions

The Regional Trial Court (RTC) of Quezon City, Branch 77, rendered a Summary Judgment ordering Ontimare Sr. to pay:

Actual and compensatory damages amounting to P75,000 per month from July 1996 to September 1998,
P150,000 for reimbursement of damage to the wood parquet floors, wall paintings, and ceiling,
P50,000 as exemplary damages, and
P30,000 for attorney’s fees.

The Court of Appeals (CA) modified the award, granting:

Compensatory damages amounting to P288,000 for unrealized income for some apartments and additional bank amortization interest from July 1996 to July 1997 totaling P344,875.74,
P150,000 for reimbursement related to physical damages,
P50,000 as exemplary damages, and
P30,000 for attorney’s fees.

While the case was on appeal, Ontimare Sr. died, and his sons (the petitioners) filed a petition for review on certiorari.

Points Raised on Appeal

The petitioners contended that the summary judgment was improperly rendered given that:

Summary judgment is proper only when there is no genuine issue of material fact apart from the amount of damages.
In this case, disputed facts existed and the proceeding resembled a trial on the merits rather than a mere summary judgment.

The petitioners further challenged:

The computation of damages relating to unearned rent and bank interest amortization, and
The imposition of exemplary damages on the ground that Ontimare Sr. acted in good faith in protecting his rights.

Respondents maintained that:

Ontimare Sr. had effectively waived his right to contest the summary judgment by not objecting to the resolution on the merits, and
The evidence—including eyewitness accounts and documentary receipts—substantiated the damages incurred and the imposition of exemplary damages for his bad faith actions.

Issues:

Procedural Issue Regarding the Summary Judgment

Whether the summary judgment rendered by the trial court was proper given that:

Summary judgment requires a lack of genuine issues of material fact (except with regard to the quantum of damages), and
The moving party must be entitled to a judgment as a matter of law.

Whether the presentation of evidence during a prolonged trial indicated that the proceeding was effectively a judgment on the merits and not suitable for summary judgment.

Substantive Issue on the Liability for Damages

Whether petitioners (as substitutes for Ontimare Sr.) are liable for the damages awarded, especially:

The compensatory damages computed in relation to unrealized income and bank interest amortization,
The period for the computation of such damages given the timeline of permits and construction, and
The award of exemplary damages in view of the alleged absence of bad faith.

The issue also encompasses the proper period for damage computation and the evidentiary basis for holding the defendant accountable for the delay in construction work and subsequent damages.

Ruling:

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Ratio:

(Subscriber-Only)

Doctrine:

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Case Digest (G.R. No. 94571) Core Legal Reasoning Model Expanded

Facts:

Case Digest (G.R. No. 94571) Expanded Legal Reasoning Model

Facts:

Issues:

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Doctrine:

Case Digest (G.R. No. 94571)
Core Legal Reasoning Model

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Case Digest (G.R. No. 94571)
Expanded Legal Reasoning Model