Ruks Konsult v. Adworld Sign
REITERATIONFacts
The Antecedents: Adworld Sign and Advertising Corporation (Adworld) filed a complaint for damages against Transworld Media Ads, Inc. (Transworld) and Comark International Corporation (Comark). Adworld alleged that its billboard structure was misaligned and its foundation impaired when the adjacent billboard structure owned by Transworld and used by Comark collapsed and crashed against it. Adworld demanded payment for repairs and loss of rental income. Transworld admitted the damage but failed to pay. Adworld filed a complaint for damages amounting to ₱474,204.00. Procedural History: The Regional Trial Court (RTC) of Makati City, Branch 142, ruled in favor of Adworld, holding Transworld and Ruks Konsult and Construction (Ruks) jointly and severally liable for ₱474,204.00 as actual damages, plus legal interest and attorney's fees. The RTC found both Transworld and Ruks negligent in the construction of the collapsed billboard, citing a weak foundation that posed a danger. Transworld and Ruks appealed to the Court of Appeals (CA). The CA dismissed Transworld's appeal for failure to file an appellant's brief. The CA subsequently denied Ruks's appeal and affirmed the RTC's ruling. Ruks filed a motion for reconsideration, which was denied. Transworld filed another appeal, which was also denied by the Supreme Court. The Petition: Ruks filed a petition for review on certiorari, assailing the CA's decision affirming the RTC's ruling that held Ruks jointly and severally liable with Transworld for damages sustained by Adworld.
Issue(s)
Whether the Court of Appeals (CA) correctly affirmed the Regional Trial Court (RTC) ruling declaring Ruks Konsult and Construction (Ruks) jointly and severally liable with Transworld Media Ads, Inc. (Transworld) for the damages sustained by Adworld Sign and Advertising Corporation (Adworld).
Ruling
The petition is without merit. The Decision dated November 16, 2011 and the Resolution dated December 10, 2012 of the Court of Appeals in CA-G.R. CV No. 94693 are hereby AFFIRMED, holding Ruks jointly and severally liable with Transworld for damages sustained by Adworld.
Ratio Decidendi
On Issue 1: The Supreme Court (SC) ruled that Ruks Konsult and Construction (Ruks) is indeed solidarily liable as a joint tortfeasor. Applying the definition from Bank of the Philippine Islands v. Lifetime Marketing Corporation, the Court found Ruks negligent for failing to observe the degree of care and precaution demanded by the circumstances. Ruks admitted that it was aware the foundation provided by Transworld Media Ads, Inc. (Transworld) was weak, yet it proceeded to install the upper billboard structure while 'merely assuming' Transworld would reinforce the base. This act, combined with Transworld's initial failure to provide a proper foundation, constituted two successive acts of negligence that were the direct and proximate cause of the single injury to Adworld Sign and Advertising Corporation (Adworld). Citing People v. Velasco, the SC explained that where several causes producing an injury are concurrent and each is an efficient cause, the injury may be attributed to all responsible persons. Under Article 2194 of the Civil Code, responsibility for a quasi-delict is solidary when two or more persons are liable; thus, Ruks and Transworld are each liable as principals for the entire damage regardless of their relative culpability.
Main Doctrine
Joint tortfeasors are solidarily liable for the entire damage caused by their concurrent or successive negligent acts or omissions, even if it is impossible to determine the proportion of each actor's contribution to the injury.