Case Digest (G.R. No. 98695)
Case Digest (G.R. No. 98695)
Facts:
Juan J. Syquia, Corazon C. Syquia, Carlota C. Syquia, Carlos C. Syquia and Anthony C. Syquia v. The Honorable Court of Appeals and Manila Memorial Park Cemetery, Inc., G.R. No. 98695, January 27, 1993, Supreme Court Second Division, Campos, Jr., J., writing for the Court.
The petitioners are the parents and siblings of the late Vicente Juan Syquia; the private respondent is Manila Memorial Park Cemetery, Inc. On March 5, 1979 the Syquias filed Civil Case No. Q-27112 in the then Court of First Instance alleging breach of contract and/or quasi-delict arising from the burial and subsequent exhumation of Vicente Juan Syquia. They asserted that under a Deed of Sale (Exhibit D, dated August 27, 1969) and an interment order, the cemetery was obliged to provide a sealed concrete vault; when the vault was later lifted preparatory to transfer, a three-inch hole and evidence of water and silt inside the vault were discovered, and when opened the coffin, lining, clothing and exposed remains were soiled and damaged.
The trial court dismissed the complaint, finding no contractual warranty that the vault be waterproof, and concluding there was no negligence given the pre-existing contractual relation and the explanation that a hole had been bored to prevent the vault from floating and the grave from caving in. The Syquias appealed to the Court of Appeals, which, in a decision penned by Associate Justice Arturo B. Buena dated December 7, 1990, affirmed the dismissal; its denial of the Syquias’ motion for reconsideration was affirmed by resolution dated April 25, 1991. The Syquias then filed the present petition to the Supreme Court seeking reversal, arguing that the cemetery breached its contractual obligation to provide a sealed (waterproof) vault, that boring the hole constituted desecration and/or negligence (culpa aquiliana), and that damages including agreed actual damages and moral, exemplary and attorneys’ fees should have been awarded.
Issues:
- Did Manila Memorial Park Cemetery, Inc. breach its contract with the Syquias by providing a concrete vault that was not waterproof as alleged?
- Alternatively, was the cemetery liable in culpa aquiliana (quasi-delict) or culpa contractual for boring a hole in the vault that allowed flooding and damage?
- Were the petitioners entitled to the damages they sought (including the agreed P25,000 actual damages, moral and exemplary damages, and attorneys’ fees)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)