Title
Ngo Sin Sing vs. Li Seng Giap and Sons, Inc.
Case
G.R. No. 170596
Decision Date
Nov 28, 2008
Petitioners' contractor caused structural damage to respondent's adjacent building during excavation. Court found contractor primarily liable, respondent contributorily negligent for unapproved modifications, reducing damages. Attorney's fees denied.

Case Summary (G.R. No. 257821)

Factual Background

The case stems from a construction project undertaken by the petitioners on a lot they owned in Binondo, where they constructed a five-storey building known as the NSS Building. They hired Contech Construction Technology Development Corporation as the general contractor for this project. The adjacent property, owned by the respondents, was the LSG Building, which began experiencing structural defects, such as cracks and sagging, allegedly due to excavation work conducted near the common boundary during the NSS Building's construction.

Initial Findings and Responses

Despite assurances from the petitioners that repairs to the LSG Building would be undertaken following complaints from respondents, further defects persisted. In 1981, an engineering firm concluded that these issues resulted from differential settlement caused by the excavation related to the NSS Building, ultimately recommending the complete demolition of the LSG Building. The respondents sought substantial damages from the petitioners and Contech, which the petitioners contested on the grounds that the LSG Building had pre-existing structural deficiencies.

Proceedings in Trial Court

The trial court found the defendants—petitioners and Contech—negligent, concluding that insufficient precautions were taken during excavation. However, it also noted that the LSG Building had been structurally unstable due to additional floors added post-reconstruction, contributing to the building's failures. As a result, the trial court held both parties accountable and entitled the respondents to a significant portion of the claimed damages.

Appeals and Court of Appeals' Rulings

Both parties appealed the trial court's decision to the Court of Appeals. The appellate court affirmed the trial court's conclusions but ruled that the responsibility for the damage should fall entirely on both petitioners and Contech, dismissing any contributory negligence on the part of the respondents. It concluded that the petitioners, as property owners, bore ultimate responsibility for ensuring their construction project did not impair adjacent land and buildings.

Supreme Court's Review and Conclusions

Upon reviewing the case, the Supreme Court considered that while both parties exhibited negligence, the trial court's findings were more aligned with the evidence presented. The Court determined that the LSG Building’s foundation was inadequate to support the additional floors built, which contributed to the structural issues experienced. Thus, the appellate court's findings were incorrect in attributing all liability to the petitioners and Contech, without acknowledging the respondents’ share

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