G.R. No. 98695 - Syquia vs. Court of Appeals

Petitioners Juan J. Syquia and Corazon C. Syquia (parents), and Carlota C. Syquia, Carlos C. Syquia, and Anthony C. Syquia (siblings) are relatives of the deceased Vicente Juan Syquia.
On March 5, 1979, the petitioners filed a complaint against Manila Memorial Park Cemetery, Inc. for damages arising from breach of contract and/or quasi-delict related to the interment of the deceased.

The parties entered into a Deed of Sale (Contract No. 6885) dated August 27, 1969, including an Interment Order No. 7106 dated July 21, 1978.
Under the said contract, the petitioners authorized the cemetery to inter the remains of the deceased at Manila Memorial Park Cemetery according to its interment procedures.

On September 4, 1978, in preparation for transferring the remains to a new family plot, the concrete vault enclosing the coffin was removed with the assistance of cemetery employees.
Petitioners discovered a hole approximately three inches in diameter near the bottom of the vault wall, from which water drained for about one hour.
The petitioners became concerned that water had flooded the coffin, affecting the deceased’s remains adversely.

With court authorization, the concrete vault was opened on September 15, 1978, assisted by licensed morticians and cemetery personnel.
Findings included:

Interior walls showed evidence of total flooding.
The coffin was severely damaged by water, filth, and silt, causing warping, separation, and cracking of the viewing glass.
The lining, clothing, and exposed remains were soiled and coated with filth.

The petitioners alleged breach of contract for failure to provide a defect-free, sealed concrete vault that would protect against the elements.
Alternatively, they argued gross negligence (culpa aquiliana) for failing to properly seal the vault under Article 2176 of the Civil Code.
They sought actual damages of P30,000, moral damages of P500,000, exemplary damages, attorney’s fees (20% of liability), litigation expenses, and costs of suit.

The contract did not guarantee the vault would be waterproof.
Manila Memorial Park Cemetery was not negligent, as the contract existed and the burial site selected by Juan Syquia required constant watering, which would naturally seep into the vault.
The hole in the vault was justified to prevent the vault from floating and the grave from caving due to water accumulation.

The Court of Appeals affirmed the trial court’s dismissal of the complaint.
The petitioners’ motion for reconsideration was denied.
The petitioners elevated the case to the Supreme Court contesting the rulings on contractual terms, justifiability of boring the hole, existence of desecration, and absence of damages awarded.

The primary issue focused on whether the cemetery breached its contract or was liable in tort for the damage to the remains caused by water entering through the hole in the vault.
The Court acknowledged the petitioners’ sentiments but ultimately found insufficient factual and legal basis to reverse the lower courts.

Whether the Manila Memorial Park Cemetery, Inc. breached the contract by providing a vault that was not waterproof or sealed as claimed by the petitioners.
Whether the act of boring a hole on the concrete vault constituted negligence or a tortious act (quasi-delict) causing damages.
Whether the damage to the coffin and remains amounted to desecration actionable under the law.
Whether the petitioners were entitled to actual damages, moral damages, exemplary damages, and attorneys’ fees.