Spouses Guanio v Makati Shangrila, G.R. No. 190601, Feb. 7, 2011 CASE DIGEST

Facts:

    For their wedding, the petitioner spouses booked at the Shangri-la Hotel Makati. Prior to the event, the parties agreed on a final price on the food to be served during the wedding reception. A day before the event, the parties finalized and forged their contract. The petitioners claim that the respondent failed to honor their agreement as stated in the contract. Petitioners thus sent a letter-complaint to the Makati Shangri-la Hotel and Resort, Inc. (respondent) and received an apologetic reply from the hotel’s Executive Assistant Manager. They nevertheless filed a complaint for breach of contract and damages. In its answer, the respondent claimed that the petitioner failed to inform the former of the change in the expected number of guest which led to the poor service.

Issue:

    WoN respondent failed to honor their contract?

Ruling:

(Article 1170; 1171; 1338; 1344)

    No, the respondents did not fail to honor their contract.

    Breach of contract is defined as the failure without a 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 the 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, as the parties’ contract provides, the respondent from liability for "any damage or inconvenience" occasioned thereby. As for petitioners’ claim that respondent departed from its verbal agreement with petitioners, the same fails, given that the written contract which the parties entered into the day before the event, being the law between them.

    In the present petition, under considerations of equity, the Court deems it just to award by way of nominal damages to petitioners, for the discomfiture that they were subjected to during to the event. 

(Alternative)

Issue:

    WoN the doctrine of proximate cause is applicable to the case?

Ruling:

    No, the doctrine of proximate cause is no applicable.

    The doctrine of proximate cause is applicable only in actions for quasi-delicts, not in actions involving breach of contract. The doctrine is a device for imputing liability to a person where there is no relation between him and another party. In such a case, the obligation is created by law itself. But, where there is a pre-existing contractual relation between the parties, it is the parties themselves who create the obligation, and the function of the law is merely to regulate the relation thus created.

Legaspi Oil v CA, G.R. No. 96505, July 1, 1993 CASE DIGEST

Facts:

    The case involves the sale of copra by Oseraos to the petitioner. A signed contract on behalf of Oseraos was entered into by both parties whereby Oseraos shall deliver to the petitioner the said copras. Oseraos failed to deliver the whole volume of copra he was obliged to deliver. The petitioner demanded the delivery of said copras but Oseraos refused because the prices of copra had gone up from the time they had entered into the contract.

Issue:

    WoN Oseraos' failure to deliver the copra is the fraud referred to by Article 1170?

Ruling:

(Article 1170; 1171; 1338; 1344)

    Yes, Oseraos' failure to deliver the copra is the fraud referred to by Article 1170.

    The fraud referred to in Article 1170 is the deliberate and intentional evasion of the normal fulfillment of the obligation. The conduct of Oseraos clearly manifests his deliberate intent to evade his contractual obligation for the price of copra had gone up.

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"Fiat justicia, ruat coelum"

Juan Syquia v CA, G.R. No. 98695, Jan. 27, 1993 CASE DIGEST

 Facts:

     The petitioner filed a complaint against Manila Memorial Park Cemetery, Inc. for the damage caused against the deceased Vicente Juan J. Syquia's remains buried in said memorial park. The damage caused happened upon the removal, for transfer on a different plot of land, of the deceased remains. The damage became apparent upon the opening the vault where the interior walls of the concrete vault showed evidence of total flooding; the coffin was entirely damaged by water, filth, and silt causing the wooden parts to warp and separate and to crack the viewing glass panel located directly above the head and torso of the deceased; and the entire lining of the coffin, the clothing of the deceased, and the exposed parts of the deceased's remains were damaged and soiled by the action of the water and silt and were also coated with filth. Due to the alleged unlawful and malicious breach by the defendant of its obligation to deliver a defect-free concrete vault designed to protect the remains of the deceased and the coffin against the elements which resulted in the desecration of the deceased's grave and in the alternative, because of defendants gross negligence in failing to seal the concrete vault petitioners filed this complaint.

Issue:

    WoN the Manila Memorial Park Cemetery, Inc. is liable for damages?

Ruling:

(Article 1170; 1171; 1338; 1344)

    No, the Manila Memorial Park Cemetery, Inc. is not liable for damages.

    There was no stipulation in the Deed of Sale and Certificate of Perpetual Care and in the Rules and Regulations of the Manila Memorial Park Cemetery, Inc. that the vault would be waterproof. Well settled is the rule that when the terms of the contract are clear and leave no doubt as to the intention of the contracting parties, then the literal meaning of the stipulation shall control.

PNCC v NLRC, G.R. No. 81551, April 27, 1989 CASE DIGEST

 Facts:

    Petitioner and Nicolas Saceda entered into a contract of employment for two years. On January 8, 1984, Saceda completed his contract and the petitioner extended it to January 27, 1984. On February 9, 1984, Saceda was dispatched to Jeddah, Saudi Arabia for immediate repatriation to the Philippines. He was first booked on February 21, 1984, however, Saceda refused to depart because he wanted to wait for the final disposition on the complaint he filed against the petitioner for the payment of his bonus, unused vacation/sick leave, and unpaid wages from December 1, 1983 up to January 27, 1984. The decision of the Saudi labor authorities which was favorable to Saceda was rendered on March 24, 1984. Saceda agreed to be repatriated on March 27, 1984, after the petitioner paid him the award granted by the Saudi labor authorities. Upon his arrival, he found out that 70% of his salary for the period November 16, 1983 to January 15, 1984 was not paid by the petitioner. Saceda then filed a complaint with the Philippine Overseas Employment Administration for non-payment of salary and stand-by pay corresponding to January 27, 1984 to March 27, 1984. He claimed that he was not repatriated soon upon the termination of his contract but was made to wait and remain idle for two months.

Issue:

    WoN the stand-by pay be paid to Saceda?

Ruling:

(Article 1170; 1171; 1338; 1344)

    Yes. It was the petitioners obligation to get Saceda's travel documents ready for his termination of the contract, the petitioner must answer in damages for the delay in Saceda's departure which compelled him to stand-by idle and jobless in a foreign land while waiting for his employer to hand him his ticket and travel papers for his trip home.

Juan Perez v CA, G.R. No. 107737, Oct. 1, 1999 CASE DIGEST

 Facts:

    The petitioner is a usufruct of a parcel of land known as Papaya Fishpond. The petitioner entered into a contract of lease with Luis Keh for a period of five years, renewable for five years. The lease contract stated that Keh cannot sublease and cannot assign rights to anyone. The respondent Luis Crisostomo acquired possession of the aforementioned parcel of land from Keh through an agreement called "pakiao buwis". The petitioners re-acquired possession by force; while Keh surrendered possession to them via a letter.

Issue:

    WoN Crisostomo is a sublessee of the fishpond?

Ruling:

(Article 1244, par. 2; 1168)

    Yes, Crisostomo is a sublessee of the fishpond.

    The lease contract prohibited petitioner Luis Keh, as lessee, from subleasing the fishpond. In entering into the agreement for pakiao-buwis with the private respondent, not to mention the apparent artifice that was his written agreement with petitioner Lee on January 9, 1978, petitioner Keh did exactly what was prohibited of him under the contract — to sublease the fishpond to a third party.

    That the agreement for pakiao-buwis was actually a sublease is borne out by the fact that the private respondent paid petitioners Luis Keh and Juan Perez, through petitioner Tansinsin the amount of annual rental agreed upon in the lease contract between the usufructuaries and petitioner Keh. Petitioner Keh led the private respondent to unwittingly incur expenses to improve the operation of the fishpond. By operation of law, therefore, petitioner Keh shall be liable to the private respondent for the value of the improvements he had made in the fishpond or for P486,562.65 with an interest of six percent (6%) per annum from the rendition of the decision of the trial court on September 6, 1989.

Metropolitan Bank and Trust Company v Rosales, G.R. No. 183204, January 13, 2014 CASE DIGEST

 Facts:

    The respondent and her mother open a joint peso account with one of the petitioners' branches, this was around the year 2000. In May of 2002, the respondent accompanied her client Liu Chiu Fang to open a savings account with the petitioner. The respondent acted as an interpreter on behalf of her client. On March 3, 2003, the respondent opened with the petitioner a joint dollar account. On July 31, 2003, the petitioner issued a "Hold Out' order against the respondents' accounts. On September 3, 2003, the petitioner filed a criminal case for estafa against the respondent, accusing the respondent as the ones responsible for the unauthorized and fraudulent withdrawal from Liu Chiu Fangs's dollar account. The case was dismissed for lack of probable cause. On September 10, 2004, the respondent filed a complaint for breach of obligation and contract against the petitioner. The respondent alleged that they attempted several times to withdraw their deposits but were unable to because petitioner had place their accounts under "Hold Out" status without any explanation as to why it issued saif status. The petitioner alleged that respondent have no cause of action because it had a valid reason for issuing the "Hold Out" order. It averred that due to the fraudulent scheme of the respondent, it was compelled to reimburse Liu Chiu Fang and to file a criminal complaint of estafa against her.

Issue:

    WoN petitioner has an obligation to release the deposit  accounts of the respondent?

Ruling:

(Article 1162; 2176; 2180)

    Yes, the petitioner has an obligation to release the deposit accounts of the respondent.

    Bank deposits, which are in the nature of a simple loan or mutuum, must be paid upon demand by the depositor.

    The "Hold Out" clause applies only if there is a valid and existing obligation from any of the sources of obligation enumerated in Article 1157 of the Civil Code.

    Petitioner failed to show that respondents have an obligation to it under any law, contract, quasi-contract, delict, or quasi-delict.

    Considering that respondent is not liable under any of the five sources of obligation, there was no legal basis for petitioner to issue the "Hold Out" order.

Villegas, et. al. v CA, G.R. Nos. 82562 and 82592, April 11, 1997 CASE DIGEST

 Facts:

    This case originated from a libel suit filed by Antonio V. Raquiza against Antonio J. Villegas, who denied the charge. Villegas left for the United States where he stayed until his death on November 16, 1984. The trial proceeded on absentia by the time of his death. The prosecution had already rested its case two months after his death. The court issued an order dismissing the criminal aspect of the case but reserved the right to resolve its civil aspect. The lower court ordered the estate of Villegas to pay civil damages with regard to the offence. The heirs of Villegas appealed the decision whereby the Court of Appeals affirmed the trials courts' judgement, modified only with respect to the award of damages.

Issue:

    WoN the death of Villegas before final judgement extinguished his civil liability?

Ruling:

(Article 1162; 2176; 2180; RPC Art. 103)

    Yes, the death of Villegas before final judgement extinguished his civil liability.

    The source of Villegas's civil liability in the present case is the felonious act of libel he allegedly committed. If the Court ruled in Bayotas that the death of an accused during the pendency of his appeal extinguishes not only his criminal but also his civil liability unless the latter can be predicated on a source of obligation other than the act or omission complained of, with more reason should it apply to the case at bar where the accused died shortly after the prosecution had rested its case and before he was able to submit his memorandum and all this before any decision could even be reached by the trial court.

    However, the enforcement of a deceased accused's civil liability is dependent on two factors, namely, that it be pursued by filing a separate civil action and that it be made subject to the Rules of Criminal Procedure. Obviously, in the case at bar, the civil action was deemed instituted with the criminal. There was no waiver of the civil action and no reservation of the right to institute the same, nor was it instituted prior to the criminal action. What then is the recourse of the private offended party in a criminal case such as this which must be dismissed in accordance with the Bayotas doctrine, where the civil action was impliedly instituted with it?

    Hence, logically, the court a quo should have dismissed both actions against Villegas which dismissal will not, however, bar Raquiza as the private offended party from pursuing his claim for damages against the executor or administrator of the former's estate, notwithstanding the fact that he did not reserve the right to institute a civil separate civil action based on Article 33 of the Civil Code.

People of the Philippines v Bayotas, G.R. No. 102007, September 2, 1994 CASE DIGEST

 Facts:

    The respondent Rogelio Bayotas was charged with rape and eventually convicted thereof on June 19, 1994. Pending the appeal of his conviction, Bayotas died on February 4, 1992. Consequently, the Supreme Court dismissed the criminal aspect of the appeal. However, it required the Solicitor General to file its comment with regard to the civil liability arising from the offense charged. The OSG expressed his view that the death of Bayotas did not extinguish his civil liability. The counsel of Bayotas opposed the view of the OSG arguing that the death of Bayotas while judgement of conviction was pending appeal extinguishes both criminal and civil penalties.

Issue:

    WoN Bayotas' civil liability is extinguished by his death?

Ruling:

(Article 1162; 2176; 2180; RPC Art. 103)

    Yes, Bayotas's death extinguished his civil liability.

    Death of the accused pending appeal of his conviction extinguishes his criminal liability as well as the civil liability based solely thereon.

    The death of the accused prior to final judgement terminates his civil liability and only the civil liability arising from and based solely on the offence committed, i.e. civil liability ex delicto in seso strictiore.

    Corollarily, the claim for civil liability survives notwithstanding the death of the accused, if the same may also be predicated on a source of obligation other than delict.

Dela Llano v Biong, G.R. No. 182356, December 4, 2013 CASE DIGEST

 Facts:

    The case involves a vehicular accident involving the petitioner and one Joel Primero, wherein the petitioner suffered injuries. The respondent is the employer of Primero. The accident happened on March 30, 2000. On October 16, 2000. the petitioner demanded from the respondent compensation for her injuries, but the respondent refused to pay. The petitioner sued the respondent for damages, alleging that she lost the mobility of her arm as a result of the accident. The respondent maintained that the petitioner had no cause of action against her as no reasonable relation existed between the vehicular accident and her injuries. She pointed out that the illness became manifest one month and one week from the date of the accident.

Issue:

    WoN petitioner can claim compensation for her injuries against the respondent?

Ruling:

(Article 1162; 2176; 2180)

    No, the petitioner cannot claim compensation for her injuries against the respondent.

    The source of obligation in a quasi-delict is the breach or omission of mutual duties that civilized society imposes upon its members, or which arise from non-contractual relations of certain members of society to others. The petitioner must first establish by a preponderance of evidence the three elements of quasi-delict before we determined the respondents' liability as Joel's employer. She should show the chain of causation between Joel's reckless driving and her whiplash injury. The rationale for these graduated levels of analysis is that it is essentially the wrongful or negligent act or omission itself which creates the vinculum juries in extra-contractual obligations.