Case Summary (G.R. No. 190601)
Breach of Contract and Exculpatory Clause
– Breach defined as failure without legal excuse to perform contractual promise (Art. 1157, 1170).
– Contract provision 4.5 required 48-hour prior notice of changes in guaranteed covers; failure to notify absolved hotel of resulting inconvenience.
Admission-by-Apology Letter
– Industry practice: standard apology to acknowledge guest concerns pending investigation, without conceding liability (Kalalo v. Luz).
– Testimony of Catering Director confirmed apology as procedural courtesy.
Equity and Nominal Damages
– Despite exculpatory clause, respondent’s scheduling lapse and service deficiencies warranted recognition of petitioners’ discomfiture.
– Under Civil Code Article 2222, nominal damages appropr
Case Syllabus (G.R. No. 190601)
Facts
- Petitioners booked Makati Shangri-La Hotel for their wedding reception on July 28, 2001, and scheduled two food tastings prior to the event.
- During the initial tasting, petitioners requested servings for seven persons but received only six; they selected a menu of black cod, king prawns and angel hair pasta at ₱1,000 per person, then substituted salmon at ₱950 per person.
- At the final tasting three days before the reception, petitioners observed that the salmon portion was half the size previously served and were quoted ₱1,200 per person for the original size.
- After negotiation, the parties agreed on a final menu price of ₱1,150 per person and executed a Banquet and Meeting Services Contract on July 26–27, 2001, with a Banquet Event Order signed July 25, 2001.
- On July 27, petitioners brought wine and liquor under an open bar arrangement.
Alleged Breach and Complaints
- Petitioners claimed respondent’s catering director and sales manager failed to be present during the reception despite assurances.
- Guests experienced delays in dinner service; certain items from the published menu were unavailable.
- Hotel waiters were allegedly rude and unapologetic when confronted about service delays.
- Alvarez had promised no charge for reception extension beyond midnight, yet petitioners were billed ₱8,000 per hour for three hours of extension.
- Petitioners’ wine and liquor were not served; guests had to pay for drinks.
- Petitioners sent a letter-complaint; respondent’s Executive Assistant Manager for Food and Beverage, Krister Svensson, replied with an apology.
Trial Court Proceedings
- Petitioners filed a complaint for breach of contract and damages with the