Sps. Guanio v.

Makati Shangri-la1
G.R. No. 190601 February 7, 2011
J. Carpio-Morales

Topic: Violation of Human Dignity

Petitioners: SPOUSES LUIGI M. GUANIO and ANNA HERNANDEZ-GUANIO

Respondents: MAKATI SHANGRI-LA HOTEL and RESORT, INC.
Summary + Doctrine: Luigi and Anna Guanio booked Makati Shangri-la for their wedding reception. Because of the
hotel’s subpar service during the event, the couple sued for breach of contract and damages. The
SC cited the essence of Article 26 (every person is entitled to respect of his dignity, personality,
privacy and peace of mind) to justify the award of nominal damages (P 50,000) in favor of the
couple.
FACTS:
 For their wedding reception on July 28, 2001, Luigi Guanio and Anna Hernandez-Guanio booked2 Shangri-la
Hotel Makati
 In the couple’s point-of-view, several mishaps attended the preparations leading up to the event and the reception
itself:
o During initial food tasting, only 6 plates were prepared by the hotel when the couple supposedly
requested for seven. In addition, their P 1,000 per person menu was supposed to comprise of black cod,
king prawns, and angel hair pasta, but instead they were served salmon instead of king prawns (P 950
per person)
o During final food tasting, the salmon served to the food tasters was half the size of what the hotel served
during the initial food tasting. Strangely, the hotel quoted a higher price for each plate – P 1,200 – which
was haggled down to P 1, 150 per person.
o During reception, Catering Director Bea Marquez and Sales Manager Tessa Alvarez, didn’t show up
despite their assurance that they would; 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; the wine and liquor brought by the couple were not
served to the guests; 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 ₱8,000 per hour for the three-hour
extension of the event up to 4:00 A.M. the next day.
 The couple sent a letter-complaint to Makati Shangri-la and they received an apologetic reply3 from the hotel’s
Exec. Asst. Manager, Krister Svensson.
 The couple nevertheless filed a complaint for breach of contract and damages before the Makati – RTC
 In its answer, the hotel claimed that:
o The meals’ higher price point was justified since the hotel served a combination of king prawns and
salmon during the reception
o Marquez and Alvarez were present during the event but they were not permanently stationed in the
reception since the hotel was handling 3 separate functions at the same time
o The delay in food service was because of the sudden increase in guests. The hotel expected 350-380
guests, but the total number of attendees was 470
o Svensson’s reply to the couples’ letter-complaint was not an admission of liability for it was meant to
maintain goodwill amongst the hotel’s customers
 Aug. 17, 2006 – The RTC-Makati ruled in favor of the couple. It relied heavily on the apologetic tenor of
Svensson’s reply which qualified as an admission of the hotel’s subpar service

1 The factual milieu of this case is not that important as per the syllabus
2 The parties signed their Banquet and Meeting Services Contract on July 27, 2001
3 “Upon receiving your comments on our service rendered during your reception here with us, we are in fact, very distressed. Right from minor

issues pappadums served in the soup instead of the creutons, lack of valet parkers, hard rolls being too hard till a major one – slow service, rude
and arrogant waiters, we have disappointed you in all means.
Indeed, we feel as strongly as you do that the services you received were unacceptable and definitely not up to our standards. We understand
that it is our job to provide excellent service and in this instance, we have fallen short of your expectations. We ask you please to accept our
profound apologies for causing such discomfort and annoyance”
  July 27, 2009 – The CA reversed the RTC and ruled that the “proximate cause of the couples’ injury was entirely
attributable to themselves and it was the unexpected increase in their guests”

ISSUES + HOLDING:

W/N a determination of proximate causation is necessary to resolve the case at hand

NO

 Since the couple’s complaint arose from a contract, what applies is NCC 11704 and not the doctrine of proximate
cause
 In RCPI v. Verchez, the SC discussed that in cases of culpa contractual, mere proof of the existence of the contract
and the failure of its compliance justify a corresponding right of relief. The remedy serves to preserve the interests
of the promissee (creditor, oblige) that may include his "expectation interest," which is his interest in having the
benefit of his bargain by being put in as good a position as he would have been in had the contract been
performed, or his "reliance interest," which is his interest in being reimbursed for loss caused by reliance on the
contract by being put in as good a position as he would have been in had the contract not been made; or his
"restitution interest," which is his interest in having restored to him any benefit that he has conferred on the other
party. The effect of every infraction is to create a new duty, that is, to make RECOMPENSE to the one who has
been injured by the failure of another to observe his contractual obligation unless he can show proof of his
exercise of due diligence or of the attendance of fortuitous event, to excuse him from his ensuing liability.

W/N the Hotel breached its Banquet and Meeting Services Contract with the couple
NO

 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
 Ff. the contract5 between the parties, it was the couple who were remiss in their obligation to inform the hotel of
the change in the expected number of guests.

W/N Svensson’s letter-reply amounted to an extra-judicial admission of liability

NO

 It is customary for hotel management to try to smooth ruffled feathers to preserve goodwill among its clientele.
 The purpose for apologizing is to show empathy. It is made to ensure the client that the hotel is hearing them
out and that they will conduct an investigation on the matter. It is not in any way an admission of fault

W/N an award of nominal damages in favor of the couple is justified (IMPORTANT PART)
YES

 The hotel admitted that three hotel functions coincided with the couple’s reception. In the eyes of the SC, the
hotel’s delay in service might have been avoided or minimized if the hotel exercised prescience in scheduling
events. No less than quality service should be delivered especially in once-in-a-lifetime events such as
weddings
 Under considerations of equity, the SC deemed it just to award the amount of ₱50,000 by way of nominal
damages to the couple by virtue of the discomfort that they were subjected to during the event. Following
NCC 26, the SC recognized that every person is entitled to respect of his dignity, personality, privacy
and peace of mind. The hotel’s lack of prudence is an affront to this right.

4 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 for damages.
5 4.5. The ENGAGER must inform the HOTEL at least 48 hours before the scheduled date and time of the Function of any change in the
minimum guaranteed covers. In the absence of such notice, paragraph 4.3 shall apply in the event of under attendance. In case the actual number
of attendees exceed the minimum guaranteed number by ten percent (10%), the HOTEL shall not in any way be held liable for any damage or
inconvenience which may be caused thereby. The ENGAGER shall also undertake to advise the guests of the situation and take positive steps to
remedy the same.
RULING: WHEREFORE, the Court of Appeals Decision dated July 28, 2009 is PARTIALLY REVERSED.
Respondent is, in light of the foregoing discussion, ORDERED to pay the amount of ₱50,000.00 to
petitioners by way of nominal damages. SO ORDERED.