SPOUSES LUIGI M. GUANIO and ANNA HERNANDEZ- obligation thus excused, as the above-quoted paragraph 4.
5 of the
GUANIO, Petitioners, vs. MAKATI SHANGRI-LA HOTEL and parties’ contract provide, respondent from liability for “any damage
RESORT, INC., also doing business under the name of or inconvenience” occasioned thereby”
SHANGRI-LA HOTEL MANILA, Respondent.
Nevertheless, on grounds of equity, the High Court awarded
G.R. No. 190601, February 7, 2011 P50,000.00 in favour of the complainants and justified it by saying:
FACTS: Petitioner spouses, Luigi M. Guanio and Anna Hernandez- “The exculpatory clause notwithstanding, the Court notes that
Guanio, booked respondent Makati Shangri-La Hotel for their respondent could have managed the “situation” better, it being held in
wedding reception. high esteem in the hotel and service industry. Given respondent’s
vast experience, it is safe to presume that this is not its first encounter
A week before their wedding reception, the hotel scheduled a food with booked events exceeding the guaranteed cover. It is not
tasting. Eventually, the parties agreed to a package where the final audacious to expect that certain measures have been placed in case
price was P1,150.00 per person. this predicament crops up. That regardless of these measures,
respondent still received complaints as in the present case, does not
According to the complainants, when the actual reception took place, amuse.
” the respondent’s representatives did not show up despite their
assurance that they would; their guests complained of the delay in the Respondent admitted that three hotel functions coincided with
service of the dinner; certain items listed in the published menu were petitioners’ reception. To the Court, the delay in service might have
unavailable; the hotel’s waiters were rude and unapologetic when been avoided or minimized if respondent exercised prescience in
confronted about the delay; and despite Alvarez’s promise that there scheduling events. No less than quality service should be delivered
would be no charge for the extension of the reception beyond 12:00 especially in events which possibility of repetition is close to nil.
midnight, they were billed and paid P8,000 per hour for the three- Petitioners are not expected to get married twice in their lifetimes.”
hour extension of the event up to 4:00 A.M. the next day. They
further claim that they brought wine and liquor in accordance with What applies in the present case is Article 1170 of the Civil Code
their open bar arrangement, but these were not served to the guests which reads:
who were forced to pay for their drinks. They sent a letter-complaint
to hotel and received an apologetic reply from the hotel’s Executive Art. 1170. Those who in the performance of their obligations are
Assistant Manager in charge of Food and Beverage. guilty of fraud, negligence or delay, and those who in any manner
contravene the tenor thereof, are liable for damages.
They nevertheless filed a complaint for breach of contract and
damages before the Regional Trial Court (RTC) of Makati City. RCPI v. Verchez, et al. enlightens: In culpa contractual x x x the
mere proof of the existence of the contract and the failure of its
Answering, the hotel said that complainants requested a combination compliance justify, prima facie, a corresponding right of relief. The
of king prawns and salmon, hence, the price was increased to law, recognizing the obligatory force of contracts, will not permit a
P1,200.00 per person, but discounted at P1,150.00; that contrary to party to be set free from liability for any kind of misperformance of
their claim, the hotel representatives were present during the event, the contractual undertaking or a contravention of the tenor thereof. A
albeit they were not permanently stationed thereat as there were three breach upon the contract confers upon the injured party a valid cause
other hotel functions; that while there was a delay in the service of for recovering that which may have been lost or suffered.
the meals, the same was occasioned by the sudden increase of guests
to 470 from the guaranteed expected minimum number of guests of The remedy serves to preserve the interests of the promissee that may
350 to a maximum of 380, as stated in the Banquet Event Order include his “expectation interest ,” which is his interest in having the
(BEO);2 and the Banquet Service Director in fact relayed the delay in benefit of his bargain by being put in as good a position as he would
the service of the meals to complainant’s father. have been in had the contract been performed, or his “reliance
interest ,”which is his interest in being reimbursed for loss caused by
The RTC, relying heavily on the letter of the hotel’s Executive reliance on the contract by being put in as good a position as he
Assistant ruled in favour of the complainants and awarded damages would have been in had the contract not been made; or his”restitution
in their favour. interest,” which is his interest in having restored to him any benefit
that he has conferred on the other party. Indeed, agreements can
The Court of Appeals reversed the decision, noting that the proximate accomplish little, either for their makers or for society, unless they
cause of the complainant’s injury was the unexpected increase in the are made the basis for action.
number of their guests.
The effect of every infraction is to create a new duty, that is, to make
ISSUE: WON Makati Shangri-La Hotel may be held liable for RECOMPENSE to the one who has been injured by the failure of
damages. another to observe his contractual obligation unless he can show
extenuating circumstances, like proof of his exercise of due diligence
RULING: The Supreme Court reversed the Court of Appeals or of the attendance of fortuitous event to excuse him from his
decision, noting that in this case, the obligation was based on a ensuing liability.
contract, hence, the concept of proximate cause has no application.
In absolving the hotel from damages, the Supreme Court noted that:
“The appellate court, and even the trial court, observed that
petitioners were remiss in their obligation to inform respondent of the
change in the expected number of guests. The observation is reflected
in the records of the case. Petitioners’ failure to discharge such
