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Spouses Guanio V Makati Shangri-La

The Supreme Court ruled that Makati Shangri-La Hotel was liable for breach of contract when guests at a wedding reception complained about delays in service and unavailable items, as proximate cause does not apply to breach of contract cases. While an exculpatory clause excused liability for increased guests, the Court found the hotel could have managed the situation better. The Court awarded nominal damages of 50,000 pesos to the petitioners for the discomfiture during their wedding reception at the hotel.

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1K views

Spouses Guanio V Makati Shangri-La

The Supreme Court ruled that Makati Shangri-La Hotel was liable for breach of contract when guests at a wedding reception complained about delays in service and unavailable items, as proximate cause does not apply to breach of contract cases. While an exculpatory clause excused liability for increased guests, the Court found the hotel could have managed the situation better. The Court awarded nominal damages of 50,000 pesos to the petitioners for the discomfiture during their wedding reception at the hotel.

Uploaded by

Cin
Copyright
© © All Rights Reserved
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Download as DOCX, PDF, TXT or read online on Scribd
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Spouses Guanio V Makati Shangri-La 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
Facts tenor thereof, are liable for damages.
Spouses Guanio booked their wedding reception at Shangri-La Hotel
Makati. A day before the reception the parties finalized their contract. The court citing RCPI v. Verchez, et al
Petitioners claim that during the reception the guests complained of the In culpa contractual x x x the mere proof of the existence of the contract
delay in the service of their diner and some items were unavailable, the and the failure of its compliance justify, prima facie, a corresponding right
waiters were said to be rude when asked about the delay. of relief. Xxx A breach upon the contract confers upon the injured party a
Because of what happened, petitioners sent a letter complaint to Makati valid cause for recovering that which may have been lost or suffered. Xxx
Shangri-la Hotel and received an apologetic reply from Krister Svensson,
the hotels Executive Assistant Manager in charge of Food and Breach of contract is defined as the failure without legal reason to comply
Beverage. Despite the apology, they filed a complaint for breach of with the terms of a contract. It is also defined as the [f]ailure, without legal
contract and damages before the Regional Trial Court (RTC) of Makati City. excuse, to perform any promise which forms the whole or part of the
contract.
RTC ruled in favor of the petitioner and ordered the respondent to pay for  Petitioners’ failure to discharge their obligation to inform the
damages. RTC relying on the letter of Svensson observed that from the respondents of the increase in their guest excused the latter
tenor of the letter that respondent admits that the services the plaintiff liability for any damage or inconvenience occasioned thereby as
received were unacceptable and definitely not up to their standards. provided in their contract.
The respondent denied that Svensson’s letter is an admission of liability  As for petitioners claim that respondent departed from
and that it was meant to maintain goodwill to its customer. its verbal agreement with petitioners, the same fails, given that
the written contract which the parties entered into the day before
On Appeal, CA however reversed the RTC’s decision in holding that the the event, being the law between them.
proximate cause of petitioners’ injury was the unexpected increase in their  Regarding the letter of letter of Svensson, as explained by
guest. respondent Catering director the hotel’s procedure on receiving
and processing complaints is mainly to show empathy and to
Issue Whether or not Makati Shangri-La is guilty of breach of ensure the client that there will be investigation and it is not in
contract/Whether or not proximate cause is applicable to actions any way that they are admitting any fault .
involving breach of contract.
The exculpatory clause notwithstanding, the Court notes that respondent
Ruling could have managed the situation better, it being held in high esteem in
the hotel and service industry.
According to the SC, proximate cause is not applicable in the case since
petitioner’s complaint arose from a contract. “The doctrine of proximate To the Court, the delay in service might have been avoided or minimized if
cause is applicable only in actions for quasi-delicts, not in actions respondent exercised prescience in scheduling events. No less than quality
involving breach of contract.” service should be delivered especially in events which possibility of
repetition is close to nil. Petitioners are not expected to get married twice
What applies in the present case is Article 1170 of the Civil Code in their lifetimes.
The Court deems it just to award the amount of P50,000.00 by way of
nominal damages to petitioners, for the discomfiture that they were
subjected to during to the event.

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