GUANIO VS.

MAKATI SHANGRI-LA
G.R. No. 190601, 7
February 2011

Carpio-Morales, J.

FACTS:
The petitioner spouses booked their wedding reception at Makati Shangri-La Hotel. Prior to
the wedding reception, the hotel arranged a food tasting and the parties agreed to a
package of P1,150.00 per person.
Based on the complainants, during the reception, a lot of problems came up such as the
respondent’s representatives did not show up when they said they would; there was delay
in the service of the dinner; some items in the menu were not available; the waiters were
rude and unremorseful when confronted about the delay, and many others. The couple sent
a letter of complaint to the hotel and received an apology from the hotel’s Executive
Assistant Manager who was in charge of the food and beverage. Nonetheless, the couple
filed a complaint for breach of contract and damages before the RTC.
In answer to the complaint, the hotel said that while there was a delay during the meal, it
was due to the sudden increase of guests expected from a minimum number of guests of
350 to a maximum of 380 to 470 and that the delay in the service of the meals was relayed
to the complainant’s father.
The RTC ruled in favor of the complainants and awarded damages to them. The Court of
Appeals overturned the decision, stating that the proximate cause of the complainant’s
injury was the unexpected increase in the number of their guests.
Issue:
Is the Doctrine of Proximate Cause applicable in obligations arising from contracts?
Ruling:
No. The Supreme Court states that the obligation was based on a contract, therefore, the
principle of proximate cause is not applicable and it is only appropriate in actions for quasi-
delicts, not in actions involving breach of contract. Article 1170 of the Civil Code states:
“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.”
The Court also added that the petitioners were careless in their obligation to apprise the
hotel of the change in the expected number of guests. Due to the petitioners’ failure to do
such obligation excuses the respondent from liability for any damage caused.