Case Digest (G.R. No. 228150) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On February 13, 2009, Attorney Bonifacio A. Alentajan and Dr. Marilyn C. Alentajan, parents-in-law of Karlos Noel R. Aleta, checked in at Sofitel Philippine Plaza Manila with their two young sons, Carlos Marco (5) and Mario Montego (3). That afternoon, Dr. Marilyn brought the boys to the kiddie pool, which featured two slides ending over the shallow water near a lifeguard station. Mario slipped on the pool’s rugged edge and struck his head, causing a laceration; shortly thereafter, Carlos bumped his head on the slide and suffered a contusion. After first aid and immediate treatment at the hotel clinic, both children later underwent further diagnostics at Medical City, where Carlos experienced seizures. Karlos demanded compensation by letter on February 25, 2009; Sofitel denied liability on April 15, 2009. Thereafter, Karlos filed a complaint for damages in the Metropolitan Trial Court, invoking Articles 2176 and 2180 of the Civil Code. He alleged that the pool’s jagged edges, in Case Digest (G.R. No. 228150) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Incident at Sofitel Philippine Plaza (February 13, 2009)
- Attorney Bonifacio A. Alentajan and Dr. Marilyn C. Alentajan check in with petitioner’s sons Carlos (5) and Mario (3).
- At the kiddie pool, Mario slips near the lifeguard station, hits the rugged pool edge and sustains a head laceration; Carlos rides the pool slide, bumps his head and suffers a contusion.
- Immediate response
- Parents administer first aid; both children are treated by the hotel clinic physician.
- Lifeguards on duty observe but do not prevent the children’s use of the pool; warning signs on age limits are obscured by plants.
- Demand and further medical issues
- February 25, 2009 – petitioner’s demand letter seeks compensation; April 15, 2009 – Sofitel denies liability.
- June 2009 – Carlos begins to have seizures, is admitted at The Medical City, undergoes MRI and EEG, and incurs medical expenses.
- Procedural history
- July 2009 – complaint filed before the Metropolitan Trial Court for P50,000.00 actual, P100,000.00 moral, P50,000.00 exemplary damages, and P50,000.00 attorney’s fees.
- August 2011 – MTC dismisses complaint for lack of proof of negligence and proximate cause, noting the children were not registered as guests on February 13.
- October 2013 – RTC and May 11, 2016 Decision of the CA affirm the dismissal; November 2, 2016 CA resolution denies reconsideration.
- Petition for review on certiorari filed with the Supreme Court.
Issues:
- Liability under quasi-delict
- Did petitioner prove respondent’s fault or negligence and the causal nexus to his children’s injuries?
- Applicability of evidentiary doctrines
- Does the attractive nuisance doctrine apply to the pool-slide complex and compel enhanced safeguards?
- Does res ipsa loquitur permit inferring negligence and shifting the burden of proof to respondent?
- Reviewability of factual findings
- Did the Court of Appeals commit grave abuse of discretion warranting this Court’s re-examination of facts?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)