SPOUSES LUIGI M. GUANIO AND ANNA HERNANDEZ-GUANIO VS.
MAKATI SHANGRI-LA
HOTEL & RESORT, INC., also doing business under the name of SHANGRI-LA HOTEL
MANILA
G.R. No. 190601, 7 February 2011, SECOND DIVISION, (Carpio-Morales, J.)
FACTS:
Spouses Luigi and Anna Guanio (petitioner) entered into contract with Makati Shangri-La
Hotel and Resort, Inc. (respondent) for the latter to render its catering services to the formers
wedding reception.
Reportedly during the reception, respondents representatives, Catering Director Bea
Marquez and Sales Manager Tessa Alvarez did not show up; there was a delay in the service of
the dinner; certain items in the published menu were unavailable; respondents waiters were
rude and unapologetic when confronted by the guest about the delay; wine and liquor brought
by the petitioners in accordance with their open bar agreement were not served to the guests
and thus the latter were forced to pay for their drinks; and despite Sales Manager Alvarezs
promise that would be no charge for the extension of the reception beyond 12:00 midnight,
petitioners were billed PHP 8,000.00 per hour for the three-hour extension of the event which
they paid for.
In view of the foregoing, petitioners sent a letter-complaint to respondent and received
an apologetic reply from respondents Hotel Executive Assistant Krister Svenson. Nevertheless,
the former filed a complaint for breach of contract and damages before the Regional Trial Court
of Makati City.
In its Answer, respondent claimed that Marquez and Alvarez were present during the
event, albeit they were not permanently stationed thereat as they were also attending to three
other functions; that the said delay in the service dinner was occasioned by the sudden increase
of guests to 470 from the guaranteed expected minimum number of 350380. In bears
mentioning in this regard, that said increase of guests was not relayed by petitioners to
respondents beforehand which is remiss on the part of the former as they are required to do so
at least 48 hours before the scheduled date and time of the function which is stipulated in the
Banquet and Meeting Services Contract between both parties.
Notwithstanding respondents contentions, the Makati RTC rendered judgement in favor
of the petitioners and ordered respondent to pay the petitioners actual, moral and exemplary
damages; and attorneys fees.
However, on appeal, the Court of Appeals reversed the trial courts decision, it holding
that the proximate cause of petitioners injury was the increase in their guests which respondent
did not expect.
ISSUE:
Whether or not the doctrine of proximate cause is applicable to actions involving breach
of contract.
HELD:
The Supreme Court held that proximate cause is applicable only in actions for quasidelicts, not in action involving breach of contract. What applies in the instant case is rather Art.
1170 of the Civil Code which reads:
Art. 1170. Those who in the performance of their obligations are guilty of fraud,
negligence or delay, and those who in any manner contravene the tenor thereof, are
liable of damages.
The mere proof of the existence of the contract and the failure of its compliance justify a
corresponding right of relief by the injured contracting party.
However, it must be stressed that petitioners failure to inform respondent of the change
in the number of the guests is a clear failure on the part of the former to discharge such
obligation which is stipulated in the Banquet and Meeting Services Contract between them.
The failure of petitioner to inform respondent about the change in the number of guests
notwithstanding, the Court notes that respondent could have managed the situation better in
view of its vast experience in the business which warrants the safe presumption that this is not
the first time they have encountered booked events exceeding the guaranteed cover. It is
therefore reasonable to expect that certain measures are placed in case predicaments such as
the instant case crops up. That regardless of these measures, respondent still received
complaints from the petitioner. As such, the Court deems it just to award petitioners only
nominal damages.
The Decision of the Court of Appeals is PARTIALLY REVERSED.
