Title
Gotesco Investment Corp. vs. Chatto
Case
G.R. No. 87584
Decision Date
Jun 16, 1992
A theater balcony collapse injured Gloria and Lina Chatto; Gotesco was found grossly negligent for structural defects, not force majeure, and liable for damages.
A

Case Digest (G.R. No. 111230)

Facts:

  • Incident and Plaintiffs
    • On June 4, 1982, Gloria E. Chatto and her 15-year-old daughter Lina Delza Chatto went to watch the movie "Mother Dear" at the Superama I theater, owned by petitioner Gotesco Investment Corporation.
    • They purchased balcony tickets but encountered difficulty finding seats due to crowding.
    • About ten minutes after entering, the balcony ceiling collapsed, plunging the theater into darkness and causing panic.
    • Gloria and Lina were shocked and injured, managing to crawl out of the debris to the street.
  • Medical Treatment and Injuries
    • They initially sought treatment at FEU Hospital where they were confined for one day before transferring to the UST Hospital.
    • Gloria was treated from June 5 to 19, 1982; Lina from June 5 to 11, 1982.
    • Medical certificates by Dr. Ernesto G. Brion documented multiple contusions, hematomas, abrasions, and cerebral concussion for both plaintiffs, estimating recovery to take two to four weeks without complications.
    • Gloria subsequently traveled to Illinois, USA for further treatment, incurring additional medical expenses and multiple hospital visits over approximately three months.
  • Claim and Trial Court’s Findings
    • Plaintiffs sued for actual, consequential, and moral damages, including attorney’s fees and costs.
    • The trial court awarded Lina P10,000 as moral damages; Gloria P49,050.00 for actual and consequential damages, P75,000 as moral damages, and P20,000 as attorney’s fees, plus costs. Interest at 12% per annum from the date of filing was likewise awarded on damages except attorney's fees.
    • The court found that the incident was caused by the collapse of the balcony ceiling due to structural defects, not force majeure.
    • Evidence proved loss of property by Gloria and expenses incurred including transportation to the USA, medical bills, and passport costs.
    • The defendant’s alleged due diligence and maintenance measures were found inadequate; their witness, Jesus Lim Ong, admitted ignorance on the cause of the collapse.

Issues:

  • Whether the collapse of the theater ceiling was due to force majeure or construction defects.
  • Whether the trial court erred in admitting certain medical and documentary exhibits without cross-examination or proper authentication.
  • Whether the petitioner was grossly negligent in maintaining the theater premises.
  • Whether the awards for damages and attorney’s fees were supported by the evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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