Title
Huang vs. Philippine Hoteliers, Inc.
Case
G.R. No. 180440
Decision Date
Dec 5, 2012
A guest injured in a hotel pool area after hours failed to prove hotel negligence; court ruled her actions caused the injury, dismissing her claims.

Case Digest (G.R. No. 180440)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Petitioner Dr. Genevieve L. Huang, a dermatologist, was invited by hotel guest Delia Goldberg to swim at the Dusit Thani Hotel Manila pool on 11 June 1995.
    • Respondents Philippine Hoteliers, Inc. (PHI) and Dusit Thani Public Co., Ltd. (DTPCI) owned and managed the hotel; First Lepanto Taisho Insurance Corporation insured it.
  • Circumstances of the Accident
    • At about 7:00 p.m. (pool closing time), lights in the pool area were allegedly turned off and the exit door locked. In darkness, petitioner sought a house phone behind the lifeguard’s counter.
    • To reach the phone, she lifted a folding wooden countertop, which then fell and struck her head, causing a large hematoma and serious brain injury.
  • Immediate Aftermath and Medical Treatment
    • Delay in rescue: hotel staff took 20–30 minutes to unlock the door; they applied an ice pack and ointment. Petitioner refused further assistance and a waiver presented by the hotel physician.
    • Returning home, she suffered dizziness, headaches, memory loss, sleeplessness, and missed work. She underwent MRI, EEG, X-rays, and consultations with multiple neurologists and a neurosurgeon, who diagnosed post-concussion syndrome, permanent brain injury, epilepsy risk, neck sprain, and vitreous detachment in the right eye.
  • Procedural History
    • On 25 October 1995 petitioner’s counsel demanded ₱100 million for loss of future earnings; no response. She filed a Complaint for Damages on 28 August 1996 against PHI, DTPCI, and First Lepanto.
    • Respondents denied negligence, asserted adequate lighting until 10 p.m., security notices, and prompt medical assistance. They argued petitioner’s own negligence in overstaying and lifting the counter.
  • Lower Courts’ Decisions
    • Regional Trial Court (RTC), Makati City (21 February 2006): dismissed the complaint for lack of merit—petitioner’s testimony “self-serving,” no proof of dark conditions, own negligence as proximate cause, hearsay medical reports, and no insurer liability.
    • Court of Appeals (CA) (9 August 2007, Resolution 5 November 2007): affirmed RTC—found cause of action in quasi-delict, petitioner assumed risk by overstaying, lifted the counter herself, and failed to prove causal link between accident and alleged permanent injuries.

Issues:

  • Are the RTC’s and CA’s factual findings conclusive in this Rule 45 petition?
  • Are respondents PHI and DTPCI liable to petitioner by implied contract to exercise due care?
  • May petitioner base her cause of action simultaneously on breach of contract and on quasi-delict?
  • Are PHI and DTPCI liable for negligence under res ipsa loquitur or respondeat superior?
  • Were petitioner’s permanent injuries caused by the 11 June 1995 accident?
  • Is petitioner entitled to actual, moral, exemplary damages, attorney’s fees, interest, and costs?
  • Is the insurer First Lepanto directly liable to petitioner?
  • Was petitioner’s CA Motion for Reconsideration pro forma?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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