G.R. No. 209906 - Coca-Cola Bottlers Philippines, Inc. vs. Menez

Petitioner Coca-Cola Bottlers Philippines, Inc. (CCBPI) and respondent Ernani Guingona MeAez (MeAez) commenced litigation after MeAez ingested kerosene served in a Sprite bottle at Rosante Bar and Restaurant.
MeAez filed a complaint for damages against CCBPI and Rosante, praying for actual, moral, exemplary damages, attorney’s fees, and costs.

On March 28, 1995, at about 3:00 p.m., MeAez ordered two beers, a pizza, and a bottled “Sprite” at Rosante.
He drank through a straw and detected a kerosene taste and smell; he then experienced burning in his throat and nausea, and vomited before reaching the restroom.
MeAez returned the bottle, had waitresses confirm it smelled of kerosene, and took the bottle with him to report the incident to Traffic Assistant Gerardo Ovas, Jr., who accompanied him to Silliman University Medical Center (SUMC).

At SUMC, MeAez vomited in the emergency room and was confined for three days. A Rosante representative offered to pay his medical bills.
Prof. Chester Dumancas, chemist, analyzed the bottle contents and identified pure kerosene.

MeAez alleged liability under Article 2187 (quasi-delict strict liability) and prayed for damages. CCBPI moved to dismiss for failure to allege requisite elements and for failure to exhaust administrative remedies under R.A. 3720. Rosante denied liability.
The Regional Trial Court (RTC) dismissed the complaint for insufficient evidence, finding gaps in the chain of custody of the bottle and noting the clear smell of kerosene should have been noticed by Rosante staff. It also held that MeAez should have first resorted to the Bureau of Food and Drugs.

The Court of Appeals (CA) reversed the RTC, ruling that prior administrative resort was not a condition precedent under Article 2187.
The CA denied actual damages but awarded MeAez moral damages (₱200,000), exemplary damages (₱200,000), attorney’s fees (₱50,000), costs of suit, with interest.

Whether the CA erred in awarding moral damages to MeAez.
Whether the CA erred in awarding exemplary damages to MeAez.
Whether the CA erred in awarding attorney’s fees to MeAez.
Whether the CA erred in holding that exhaustion of administrative remedies with the Bureau of Food and Drugs was not necessary.