Case Digest (G.R. No. 204866) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Ruks Konsult and Construction v. Adworld Sign and Advertising Corporation and Transworld Media Ads, Inc., the respondent Adworld owned a 75 ft. × 60 ft. billboard on EDSA Tulay, Guadalupe, Mandaluyong. On August 11, 2003, the adjacent billboard built by Transworld and constructed by Ruks collapsed onto Adworld’s structure, misaligning it and impairing its foundation. Adworld sent a demand on August 19, 2003, for repair costs and loss of rental income, totaling ₱474,204.00. Transworld admitted the damage in its August 29, 2003 reply but refused payment. Adworld filed a complaint in RTC Makati (Civil Case No. 03-1452). Transworld counterclaimed that unusually strong winds caused the collapse and brought Ruks in via third-party complaint, alleging a weak foundation. Ruks answered that it merely completed the structure according to existing foundations. RTC Branch 142, in an August 25, 2009 Decision, found Transworld and Ruks negligent, holding them jointly and severally liable f Case Digest (G.R. No. 204866) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the dispute
- Adworld Sign and Advertising Corporation (Adworld) owns a 75 ft. x 60 ft. billboard at EDSA Tulay, Guadalupe, Barangka, Mandaluyong.
- On August 11, 2003, the adjacent billboard owned by Transworld Media Ads, Inc. (Transworld) and used by Comark International Corporation (Comark) collapsed, damaging Adworld’s structure.
- Pre-trial correspondence and demand for damages
- On August 19, 2003, Adworld demanded repair costs and loss of rental income (₱474,204 total).
- Transworld admitted the damage on August 29, 2003 but refused payment; Adworld’s final demand was likewise unheeded.
- Pleadings and third-party actions
- Adworld filed a complaint before the Makati RTC against Transworld and Comark for actual damages (₱281,204 materials; ₱72,000 labor; ₱121,000 income).
- Transworld’s Answer with Counterclaim: blamed extraordinary winds; filed third-party complaint against Ruks Konsult and Construction (Ruks) for alleged defective foundation.
- Comark’s Answer: denied liability and sought exemplary damages against Transworld for inclusion as party.
- Ruks’s Answer: admitted contract to build billboard but denied liability, asserting it merely completed work on an existing foundation per contract terms.
- Trial court and appellate proceedings
- RTC (Branch 142, Makati) rendered Decision (Aug 25, 2009) finding Transworld and Ruks jointly and severally liable for ₱474,204 actual damages plus legal interest and ₱50,000 attorney’s fees.
- Transworld’s appeal to the CA was dismissed for failure to file a brief; its separate petitions to the Supreme Court (G.R. No. 197601 and No. 205120) were likewise terminated or denied.
- Ruks appealed to the CA (CA-G.R. CV No. 94693); the CA Decision (Nov 16, 2011) and Resolution denying reconsideration (Dec 10, 2012) affirmed the RTC.
Issues:
- Whether the Court of Appeals correctly affirmed the RTC’s finding that Ruks is jointly and severally liable with Transworld for the damage to Adworld’s billboard.
- Whether the negligent acts and omissions of Transworld and Ruks constituted the direct and proximate cause of the alleged damage.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)