En Banc
Henson, Jr., v. UCPB General Insurance Co., Inc.
G.R.No. 223134 , August 14, 2019
PERLAS-BERNABE, J.:
FACTS:
National Arts Studio and Color Lab (NASCL) leased the front portion of
the ground floor of a two (2)-storey building owned by petitioner
Henson, Jr. NASCL transferred to the right front portion of the ground
floor and the entire second floor of the said building, and made
renovations with the building's piping assembly. Meanwhile, Copylandia
Office Systems Corp. (Copylandia) moved in to the ground floor. A water
leak occurred in the building and damaged Copylandia's various
equipment, causing injury to it in the amount of P2,062,640.00. As the
said equipment were insured with respondent UCPB, Copylandia filed a
claim with the former. Eventually, the two parties settled for the amount
of P1,326,342.76.12 This resulted in respondent's subrogation to the
rights of Copylandia over all claims and demands arising from the said
incident. Respondent, as subrogee to Copylandia's rights, demanded
from, NASCL for the payment of the aforesaid claim, but to no avail.
Thus, it filed a complaint for damages against NASCL before the RTC.
Petitioner transferred the ownership of the building to Citrinne Holdings,
Inc. (CHI), where he is a stockholder and the President.
Respondent averred that NASCL is negligent for not properly
maintaining in good order the comfort room facilities where the
renovated building's piping assembly was utilized and CHI/petitioner, as
the owner of the building, is negligent in maintaining the building's
drainage system in good order and in tenantable condition. Such
negligence on their part directly resulted in substantial damage to
Copylandia's various equipment.
The RTC ruled in respondent's favor stating that the prescriptive period
was ten years based on an obligation created by law. CHI appealed
but the Court of Appeals affirmed the decision of the RTC and likewise
denied CHI’s motion for reconsideration.
Hence, the present case.
ISSUE:
Whether or not the respondents claim has yet to prescribe.
RULING:
NO. In this case, it is undisputed that the water leak damage incident,
which gave rise to Copylandia's cause of action against any possible
defendants, including NASCL and petitioner, happened on May 9, 2006.
As this incident gave rise to an obligation classified as a quasi-delict,
Copylandia would have only had four (4) years, or until May 9, 2010,
within which to file a suit to recover damages. When Copylandia's rights
were transferred to respondent by virtue of the latter's payment of the
former's insurance claim on November 2, 2006, as evidenced by the
Loss and Subrogation Receipt, respondent was likewise bound by the
same prescriptive period.
The prevailing rule applicable to the pertinent events of this case is
Vector. As the amended complaint impleading petitioner was filed on
April 21, 2014, which is within ten (10) years from the time respondent
indemnified Copylandia for its injury/loss, i.e., on November 2, 2006, the
case cannot be said to have prescribed under Vector.
