Case Digest (G.R. No. 154259) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Nikko Hotel Manila Garden and Ruby Lim v. Roberto Reyes a.k.a. Amay Bisaya, decided on February 28, 2005, petitioners are the Hotel (now Dusit Hotel Nikko) and its longtime Executive Secretary, Ruby Lim; respondent is actor Roberto Reyes. On the evening of October 13, 1994, Reyes was in the lobby of Hotel Nikko when his friend Dr. Violeta Filart invited him to a birthday celebration for Hotel Manager Masakazu Tsuruoka in the penthouse. Filart vouched for Reyes, who carried a basket of fruits as a gift. After some hours and during the buffet dinner, Lim—tasked with guest management—told Reyes he was not invited and should leave. She allegedly spoke in a loud voice within earshot of other guests and, shortly after, a policeman escorted Reyes out, causing him public shame. Reyes filed a complaint for actual, moral and exemplary damages, plus attorney’s fees, under the human relations provisions (Articles 19, 20, 21) of the New Civil Code. At trial, Lim admitted asking Reyes to l Case Digest (G.R. No. 154259) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Cause of Action
- Petitioners: Nikko Hotel Manila Garden (now Dusit Hotel Nikko) and Ruby Lim, Executive Secretary.
- Respondent: Roberto Reyes, a.k.a. “Amay Bisaya,” actor and public figure.
- Cause: Claim for damages under the human relations provisions (Articles 19 and 21) of the New Civil Code for alleged public humiliation and shame.
- The Incident on October 13, 1994
- Around 6:00 PM, Reyes was in Hotel Nikko lobby when Dr. Violeta Filart, a long-time friend, invited him to a party at the penthouse celebrating the hotel manager’s birthday.
- Reyes carried a fruit basket as a gift and joined the party; photos were taken with the celebrant.
- When Reyes lined up for buffet dinner, Ruby Lim, claiming to speak for the hotel, loudly told him “hindi ka imbitado, bumaba ka na lang” within hearing of other guests.
- Reyes’s attempts to explain were ignored by Dr. Filart; a Makati policeman then escorted him out, heightening his embarrassment.
- Reyes sued for ₱1 million actual damages, ₱1 million moral damages, and ₱200,000 attorney’s fees.
- Defenses and Testimonies
- Ruby Lim admitted asking Reyes to leave but asserted she acted discreetly:
- She checked with a “captain waiter,” then with Filart’s sister and another guest to confirm Reyes was uninvited.
- She approached Reyes at close range, advised him to finish his food and quietly depart.
- Dr. Filart testified she never invited Reyes and thought he had already left when the commotion occurred.
- Hotel Nikko maintained Lim was enforcing an exclusive guest list (~60 persons) drafted at the celebrant’s behest.
- Procedural History
- RTC (Branch 104, Quezon City) dismissed the complaint, finding Reyes assumed the risk of removal as an uninvited guest (doctrine of volenti non fit injuria).
- Court of Appeals reversed, holding Lim’s conduct contrary to morals and good customs (Art. 21), imposed joint liability on Hotel Nikko, Lim, and Filart, and awarded exemplary (₱200,000), moral (₱200,000) damages, plus ₱10,000 attorney’s fees.
- Petitioners’ motion for reconsideration was denied; they filed for review on certiorari before the Supreme Court.
Issues:
- Whether the doctrine of volenti non fit injuria bars Reyes’s recovery.
- Whether Lim and Hotel Nikko can be held solidarily liable with Dr. Filart.
- Whether the Court of Appeals departed from the trial court’s factual findings on Lim’s manner of address.
- Whether the CA erred by inferring unjust treatment due to Reyes’s alleged poverty.
- Whether the CA improperly failed to address alleged defects in Reyes’s brief.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)