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    The spouses Guanio sued Makati Shangri-La Hotel for breach of contract regarding their wedding reception. During the reception, the hotel's representatives were absent, dinner was delayed, menu items were unavailable, and waiters were rude. Additionally, the spouses were charged extra for extending the reception despite being told there would be no additional charge. While the trial court ruled in favor of the spouses, the Court of Appeals reversed, citing proximate cause from increased guests. However, the Supreme Court held that proximate cause does not apply to breach of contract cases. It found both parties at fault—the spouses for not informing of increased guests, but the hotel could have better managed the situation. The Supreme

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    Case Digest

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    The spouses Guanio sued Makati Shangri-La Hotel for breach of contract regarding their wedding reception. During the reception, the hotel's representatives were absent, dinner was delayed, menu items were unavailable, and waiters were rude. Additionally, the spouses were charged extra for extending the reception despite being told there would be no additional charge. While the trial court ruled in favor of the spouses, the Court of Appeals reversed, citing proximate cause from increased guests. However, the Supreme Court held that proximate cause does not apply to breach of contract cases. It found both parties at fault—the spouses for not informing of increased guests, but the hotel could have better managed the situation. The Supreme

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    The spouses Guanio sued Makati Shangri-La Hotel for breach of contract regarding their wedding reception. During the reception, the hotel's representatives were absent, dinner was delayed, menu items were unavailable, and waiters were rude. Additionally, the spouses were charged extra for extending the reception despite being told there would be no additional charge. While the trial court ruled in favor of the spouses, the Court of Appeals reversed, citing proximate cause from increased guests. However, the Supreme Court held that proximate cause does not apply to breach of contract cases. It found both parties at fault—the spouses for not informing of increased guests, but the hotel could have better managed the situation. The Supreme

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    646 views2 pages

    Case Digest

    Uploaded by

    ISPat
    The spouses Guanio sued Makati Shangri-La Hotel for breach of contract regarding their wedding reception. During the reception, the hotel's representatives were absent, dinner was delayed, menu items were unavailable, and waiters were rude. Additionally, the spouses were charged extra for extending the reception despite being told there would be no additional charge. While the trial court ruled in favor of the spouses, the Court of Appeals reversed, citing proximate cause from increased guests. However, the Supreme Court held that proximate cause does not apply to breach of contract cases. It found both parties at fault—the spouses for not informing of increased guests, but the hotel could have better managed the situation. The Supreme

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    of 2

    SPOUSES LUIGI M. GUANIO AND ANNA HERNANDEZ-GUANIO VS.

    MAKATI SHANGRI-LA
    HOTEL & RESORT, INC., also doing business under the name of SHANGRI-LA HOTEL
    MANILA
    G.R. No. 190601, 7 February 2011, SECOND DIVISION, (Carpio-Morales, J.)
    FACTS:
    Spouses Luigi and Anna Guanio (petitioner) entered into contract with Makati Shangri-La
    Hotel and Resort, Inc. (respondent) for the latter to render its catering services to the formers
    wedding reception.
    Reportedly during the reception, respondents representatives, Catering Director Bea
    Marquez and Sales Manager Tessa Alvarez did not show up; there was a delay in the service of
    the dinner; certain items in the published menu were unavailable; respondents waiters were
    rude and unapologetic when confronted by the guest about the delay; wine and liquor brought
    by the petitioners in accordance with their open bar agreement were not served to the guests
    and thus the latter were forced to pay for their drinks; and despite Sales Manager Alvarezs
    promise that would be no charge for the extension of the reception beyond 12:00 midnight,
    petitioners were billed PHP 8,000.00 per hour for the three-hour extension of the event which
    they paid for.
    In view of the foregoing, petitioners sent a letter-complaint to respondent and received
    an apologetic reply from respondents Hotel Executive Assistant Krister Svenson. Nevertheless,
    the former filed a complaint for breach of contract and damages before the Regional Trial Court
    of Makati City.
    In its Answer, respondent claimed that Marquez and Alvarez were present during the
    event, albeit they were not permanently stationed thereat as they were also attending to three
    other functions; that the said delay in the service dinner was occasioned by the sudden increase
    of guests to 470 from the guaranteed expected minimum number of 350380. In bears
    mentioning in this regard, that said increase of guests was not relayed by petitioners to
    respondents beforehand which is remiss on the part of the former as they are required to do so
    at least 48 hours before the scheduled date and time of the function which is stipulated in the
    Banquet and Meeting Services Contract between both parties.
    Notwithstanding respondents contentions, the Makati RTC rendered judgement in favor
    of the petitioners and ordered respondent to pay the petitioners actual, moral and exemplary
    damages; and attorneys fees.
    However, on appeal, the Court of Appeals reversed the trial courts decision, it holding
    that the proximate cause of petitioners injury was the increase in their guests which respondent
    did not expect.
    ISSUE:

    Whether or not the doctrine of proximate cause is applicable to actions involving breach
    of contract.
    HELD:
    The Supreme Court held that proximate cause is applicable only in actions for quasidelicts, not in action involving breach of contract. What applies in the instant case is rather Art.
    1170 of the Civil Code which reads:
    Art. 1170. Those who in the performance of their obligations are guilty of fraud,
    negligence or delay, and those who in any manner contravene the tenor thereof, are
    liable of damages.
    The mere proof of the existence of the contract and the failure of its compliance justify a
    corresponding right of relief by the injured contracting party.
    However, it must be stressed that petitioners failure to inform respondent of the change
    in the number of the guests is a clear failure on the part of the former to discharge such
    obligation which is stipulated in the Banquet and Meeting Services Contract between them.
    The failure of petitioner to inform respondent about the change in the number of guests
    notwithstanding, the Court notes that respondent could have managed the situation better in
    view of its vast experience in the business which warrants the safe presumption that this is not
    the first time they have encountered booked events exceeding the guaranteed cover. It is
    therefore reasonable to expect that certain measures are placed in case predicaments such as
    the instant case crops up. That regardless of these measures, respondent still received
    complaints from the petitioner. As such, the Court deems it just to award petitioners only
    nominal damages.
    The Decision of the Court of Appeals is PARTIALLY REVERSED.

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