Case Digest (G.R. No. 190601)
Facts:
Spouses Luigi M. Guanio and Anna Hernandez-Guanio v. Makati Shangri-La Hotel and Resort, Inc., G.R. No. 190601, February 07, 2011, Supreme Court Third Division, Carpio Morales, J., writing for the Court.Petitioners booked the Shangri‑La Hotel Makati for their wedding reception on July 28, 2001. Prior to the event respondent scheduled an initial food tasting; petitioners asked the hotel to prepare for seven persons (the couple, their respective parents, and the wedding coordinator), but the hotel prepared only six. Petitioners initially selected a menu priced at P1,000 per person then accepted an alternative with salmon at P950; a subsequent final tasting three days before the event presented a smaller salmon portion and a quoted price of P1,200, later agreed at P1,150 per person. The written Banquet and Meeting Services Contract and Banquet Event Order were finalized on July 26 and 25, 2001 respectively, with the final price confirmed on July 27, 2001.
During the reception petitioners alleged several failures by respondent: Catering Director Bea Marquez and Sales Manager Tessa Alvarez did not remain on site as assured; dinner service was delayed; certain published menu items were unavailable; waiters were rude; extension of the event past midnight—despite an alleged promise of no charge—resulted in billing of P8,000 per hour for three additional hours; and petitioners’ brought wine and liquor under an open bar arrangement were not served, forcing guests to pay. Petitioners sent a complaint letter and received an apologetic reply from Executive Assistant Manager Krister Svensson; they then filed suit for breach of contract and damages in the Regional Trial Court (RTC) of Makati.
The RTC (Branch 148) rendered judgment for petitioners on August 17, 2006, awarding P350,000 actual damages, P250,000 moral damages, P100,000 exemplary damages, and P100,000 attorney’s fees, relying heavily on Svensson’s letter of apology as an admission of unacceptable service. On appeal, the Court of Appeals (pen. J. Apolinario D. Bruselas, Jr.; concurring Justices Andres B. Reyes, Jr. and Pampio A. Abarintos) reversed by Decision dated July 27, 2009, holding that the proximate cause of the complained-of problems was petitioners’ unexpected increase in guests (from guaranteed minimum 350 to 470),...(Subscriber-Only)
Issues:
- Is the doctrine of proximate cause applicable to a breach of contract action between petitioners and respondent?
- Did respondent breach the Banquet and Meeting Services Contract and incur liability for damages despite the attendance-related exculpatory clause in the contract?
- Does the hotel’s conciliatory apology letter from Executive Assistant Manager Krister Svensson constitute an admission ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)