Case Digest (G.R. No. 190601) Core Legal Reasoning Model
Facts:
In 2001, Spouses Luigi M. Guanio and Anna Hernandez-Guanio (petitioners) engaged Makati Shangri-La Hotel and Resort, Inc. (respondent) to host their wedding reception on July 28, 2001 at the hotel’s Makati premises. Two food tastings preceded the event: petitioners initially requested a menu for seven persons but were served six, chose a set menu at ₱1,000 per person, then substituted salmon at ₱950, and finally agreed on ₱1,150 per person during a second tasting. On July 27, 2001, they executed the Banquet and Meeting Services Contract and signed the Banquet Event Order guaranteeing 350 to 380 guests. During the reception, petitioners alleged respondent’s representatives failed to remain on site, dinner service was delayed, certain published menu items were unavailable, waiters behaved rudely, an extension beyond midnight was billed at ₱8,000 per hour despite assurances otherwise, and their own wine and liquor were not served under the open-bar arrangement. They paid the charg
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Case Digest (G.R. No. 190601) Expanded Legal Reasoning Model
Facts:
- Booking and Contract
- Spouses Luigi M. Guanio and Anna Hernandez-Guanio booked the Shangri-La Hotel Makati for their July 28, 2001 wedding reception.
- Initial food tasting was set for seven (the couple, their parents, coordinator) but only six were served. Petitioners chose a main course of black cod, king prawns (later replaced by salmon at P950/person), and angel hair pasta.
- In the final tasting three days before the event, salmon portions were smaller and quoted at P1,200/person. Parties negotiated P1,150/person and executed the Banquet and Meeting Services Contract on July 27, 2001.
- Reception and Complaint
- Petitioners allege Catering Director Bea Marquez and Sales Manager Tessa Alvarez failed to attend; guests suffered delays; certain menu items unavailable; waiters were rude; despite a verbal promise, they were charged P8,000/hour for three hours of extension.
- Petitioners brought wine and liquor under an open bar arrangement, but these were not served and guests paid out-of-pocket. A letter-complaint was sent; Executive Assistant Manager Krister Svensson replied with apologies.
- Litigation
- Petitioners filed a breach of contract suit in the RTC of Makati City.
- RTC Branch 148 (Aug. 17, 2006) awarded P350,000 actual damages, P250,000 moral damages, P100,000 exemplary damages, and P100,000 attorney’s fees. The trial court relied on Svensson’s apology letter as admission of liability.
- The Court of Appeals (July 27, 2009) reversed, attributing proximate cause of inconvenience to petitioners’ sudden guest increase; petitioners’ motion for reconsideration was denied Nov. 19, 2009.
Issues:
- Procedural Issue
- Whether the doctrine of proximate cause applies in an action for breach of contract.
- Substantive Issues
- Whether respondent breached its contractual obligations despite the exculpatory clause concerning changes in guaranteed guest numbers.
- Whether the apology letter from hotel management constitutes an admission of liability.
- Whether petitioners are entitled to damages, and if so, what quantum.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)