Sunday, January 24, 2016

Spouses Luigi M. Guanio and Anna Hernandez-Guanio vs. Makati Shangri-La Hotel and Resort, Inc., also doing business under the name Shangri-La Hotel Manila [GR No. 190601, February 7, 2011]

FACTS: For their wedding reception, petitioners booked at the Shangri-la Hotel Makati. Petitioners claim that during the reception, their guests complained at the delay in the service of the dinner; certain items listed in the published menu were unavailable; and the hotel waiters were rude and unapologetic when confronted about the delay. Petitioners filed a complaint for breach of contract and damages before the RTC of Makati City. Respondent however avers that while there was a delay in the service of the meals, the same was occasioned by the sudden increase of guests to 470 from the guaranteed expected minimum number of guests of 350 to a maximum of 380. The Court of Appeals held that the proximate cause of petitioners' injury was an unexpected increase in their guests.

ISSUE: Whether or not the doctrine of proximate cause applies to actions involving breach of contract

RULING: No. The doctrine of proximate cause is applicable only in actions for quasi-delicts. The doctrine is a device for imputing liability to a person where there is no relation between him and another party. In such a case, the obligation is created by law itself. But, where there is a pre-existing contractual relation between the parties, it is the parties themselves who create the obligation, and the function of the law is merely to regulate the relation thus created. In culpa contractual, the mere proof of the existence of the contract and the failure of its compliance justify, prima facie, a corresponding right of relief. A breach upon the contract confers upon the injured party a valid cause for recovering that which may have been lost or suffered. The Court deems it just to award the amount of Php50,000.00 by way of nominal damages to petitioners, for the discomfiture that they were subjected to during the event. The Court recognizes that every person is entitled to respect of his dignity, personality, privacy and peace of mind. Respondent's lack of prudence is an affront to this right.

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