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SPS. GUANIO v. MAKATI SHANGRI-LA HOTEL

The case involved a breach of contract claim by wedding reception clients against a hotel. The clients claimed issues with food service and billing during the reception. While the trial court ruled for the clients, the appellate court found the increase in unexpected guests was the proximate cause of issues. The Supreme Court disagreed that proximate cause applied, as this was a breach of contract case, not a tort case. It found the clients failed to inform the hotel of the increased guest number, excusing the hotel from liability.

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93 views2 pages

SPS. GUANIO v. MAKATI SHANGRI-LA HOTEL

The case involved a breach of contract claim by wedding reception clients against a hotel. The clients claimed issues with food service and billing during the reception. While the trial court ruled for the clients, the appellate court found the increase in unexpected guests was the proximate cause of issues. The Supreme Court disagreed that proximate cause applied, as this was a breach of contract case, not a tort case. It found the clients failed to inform the hotel of the increased guest number, excusing the hotel from liability.

Uploaded by

vcruzcruisin
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

SPS. GUANIO v.

MAKATI SHANGRI-LA HOTEL


GR No. 190601, February 7 2011

FACTS:

For their wedding reception on July 28, 2001, spouses Luigi M. Guanio and Anna
Hernandez-Guanio (petitioners) booked at the Shangri-la Hotel Makati.Prior to the event, Makati
Shangri-La Hotel & Resort, Inc. (respondent) scheduled an initial and final food tasting. The
parties eventually agreed on a final price ─ P1,150 per person.On July 27, 2001, the parties
finalized and signed their contract.

Petitioners claim that during the reception, respondent’s representatives, Catering


Director Bea Marquez and Sales Manager Tessa Alvarez, did not show up despite their assurance
that they would; their guests complained of the delay in the service of the dinner; certain items
listed in the published menu were unavailable; the hotel’s waiters were rude and unapologetic
when confronted about the delay; and despite Alvarez’s promise that there would be no charge
for the extension of the reception beyond 12:00 midnight, they were billed and paid P8,000 per
hour for the three-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 their open bar arrangement, but these were
not served to the guests who were forced to pay for their drinks.

Petitioners thus sent a letter-complaint to the Makati Shangri-la Hotel and Resort, Inc.and
received an apologetic reply from Krister Svensson, the hotel’s Executive Assistant Manager in
charge of Food and Beverage. They nevertheless filed a complaint for breach of contract and
damages before the RTC of Makati City. Respondents averred that it was the increase in number
of the unexpected guests that led to the shortage claimed by the petitioners.

The RTC rendered a decision in favor of the plaintiffs and was reversed by the CA, upon
appeal, the latter holding that the proximate cause of petitioners’ injury was an unexpected
increase in their guests.

ISSUE:

Whether or not the CA correctly held that the proximate cause of petitioners’ injury was
an unexpected increase in their guests.

HELD:

The Court finds that since petitioners’ complaint arose from a contract, the doctrine of
proximate cause finds no application to it, the latter applicable only to actions for quasi-delicts,
not in actions involving breach of contract.

Breach of contract is defined as the failure without legal reason to comply with the terms
of a contract. It is also defined as the failure, without legal excuse, to perform any promise which
forms the whole or part of the contract. 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 obligation thus excused respondent from liability for “any damage or
inconvenience” occasioned thereby.

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