Title
Aleta vs. Sofitel Philippine Plaza Manila
Case
G.R. No. 228150
Decision Date
Jan 11, 2023
Sofitel held liable for quasi-delict due to negligence in pool safety, causing injuries to children; awarded damages for suffering and negligence.
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Case Digest (G.R. No. 228150)

Facts:

Background and Incident Details:

  • On February 13, 2009, Karlos Noel R. Aleta's (Karlos) parents-in-law, Atty. Bonifacio A. Alentajan and Dr. Marilyn C. Alentajan, checked into Sofitel Philippine Plaza Manila (Sofitel). They were accompanied by Karlos's children, Carlos Marco Aleta (5 years old) and Mario Montego Aleta (3 years old).
  • Dr. Marilyn brought the children to the hotel's kiddie pool. Mario slipped near the lifeguard station, hitting his head on the rugged edge of the pool, causing it to bleed. Carlos, while using the kiddie pool slide, bumped his head and also sustained a contusion.
  • First aid was administered, and the children were treated at the hotel clinic by the hotel's physician.

Demand for Compensation:

  • On February 25, 2009, Karlos sent a letter to Sofitel's manager, Mr. Bernd Schneider, demanding compensation for his children's injuries.
  • Sofitel, through its counsel, denied the request on April 15, 2009.

Medical Complications:

  • In June 2009, Carlos began experiencing seizures and was admitted to Medical City, where he underwent MRI and EEG procedures, incurring medical expenses.

Legal Proceedings:

  • Karlos filed a Complaint for Damages against Sofitel before the Metropolitan Trial Court (MeTC), alleging negligence due to:
    1. Poor visibility of the pool steps.
    2. Jagged pool edges.
    3. Inadequate warning signs for the slide.
    4. Lack of barriers to prevent children from accessing the slide.
    5. Lifeguard negligence.
  • Karlos sought P50,000.00 in actual damages, P100,000.00 in moral damages, P50,000.00 in exemplary damages, and P50,000.00 in attorney's fees.

Sofitel's Defense:

  • Sofitel denied liability, arguing that the complaint lacked a cause of action, the incident was an accident, and Karlos failed to prove negligence.

Lower Court Decisions:

  • The MeTC dismissed the complaint, finding that Karlos failed to prove Sofitel's negligence and that the children were not authorized guests on the day of the incident.
  • The Regional Trial Court (RTC) and the Court of Appeals (CA) affirmed the MeTC's decision, ruling that Karlos failed to establish a causal connection between Sofitel's alleged negligence and the injuries.

Issue:

  1. Whether Sofitel Philippine Plaza Manila should be held liable for the injuries sustained by Karlos's children under the doctrine of quasi-delict.
  2. Whether the Court of Appeals committed grave abuse of discretion in affirming the lower courts' decisions.

Ruling:

The Supreme Court granted the petition, reversing the Court of Appeals' decision. Sofitel was held liable for quasi-delict and ordered to pay:

  1. P50,000.00 as temperate damages.
  2. P100,000.00 as moral damages.
  3. P50,000.00 as exemplary damages.
  4. P50,000.00 as attorney's fees.

Ratio:

  • (Unlock)

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