Nikko Hotel Manila Garden v. Reyes
REITERATIONFacts
The Antecedents: Respondent Roberto Reyes, a.k.a. "Amay Bisaya," alleged that while at the lobby of petitioner Nikko Hotel Manila Garden, he was invited by Dr. Violeta Filart to join a party at the hotel's penthouse for the manager's birthday. Upon reaching the penthouse and during the buffet dinner, petitioner Ruby Lim, Executive Secretary of the hotel, allegedly told Mr. Reyes in a loud voice and within the hearing of other guests to leave as he was not invited. Mr. Reyes claimed he was further humiliated when a policeman escorted him out. He filed a complaint for damages. Procedural History: The Regional Trial Court (RTC) dismissed the complaint, finding that Ms. Lim was discreet and that Mr. Reyes, as an uninvited guest, assumed the risk of being asked to leave. The Court of Appeals (CA) reversed the RTC decision, holding Ms. Lim liable for damages under Articles 19 and 21 of the Civil Code for causing Mr. Reyes embarrassment and humiliation. The CA also held Dr. Filart equally liable. The CA awarded exemplary damages, moral damages, and attorney's fees. The Petition: Petitioners Nikko Hotel Manila Garden and Ruby Lim assailed the CA decision and resolution, arguing that the CA erred in not applying the doctrine of volenti non fit injuria, in holding them jointly and severally liable with Dr. Filart, in departing from the RTC's findings of fact, and in concluding that Mr. Reyes was treated unjustly due to his poverty.
Issue(s)
Whether petitioners Nikko Hotel Manila Garden and Ruby Lim are liable for damages under Articles 19 and 21 of the Civil Code for allegedly causing humiliation to respondent Roberto Reyes. Whether the doctrine of volenti non fit injuria applies in this case, considering the obligations under Articles 19 and 21 of the Civil Code to treat individuals fairly and avoid unnecessary ridicule. Whether the Court of Appeals erred in reversing the findings of fact of the Regional Trial Court regarding the credibility of witnesses and the burden of proof.
Ruling
The petition is GRANTED. The Decision of the Court of Appeals is REVERSED and SET ASIDE. The Decision of the Regional Trial Court is AFFIRMED.
Ratio Decidendi
On the liability of Ruby Lim and Nikko Hotel Manila Garden: The Supreme Court found the RTC's findings of fact more credible. The Court noted that the incident occurred at a formal, invitation-only party. While Mr. Reyes was an actor and a public figure, Ms. Lim, as the organizer, was mindful of the celebrant's wish for an intimate gathering. The Court found it unlikely that Ms. Lim would shout at Mr. Reyes from a close distance, especially given her twenty years of experience in the hotel business where politeness and discretion are valued. Mr. Reyes's own testimony that Ms. Lim was very close to him, "nearly kissed each other," contradicted his claim that she shouted. The Court reasoned that if Ms. Lim had intended to humiliate Mr. Reyes, she would not have approached him so closely. Furthermore, Mr. Reyes failed to present any witnesses to corroborate his claim that Ms. Lim shouted. The Court concluded that Ms. Lim did not abuse her right to ask Mr. Reyes to leave, as he was an uninvited guest, and her actions were not done in bad faith or with intent to injure. Consequently, her employer, Hotel Nikko, cannot be held solidarily liable. On the application of volenti non fit injuria and the obligations under Articles 19 and 21: The Court acknowledged the doctrine of volenti non fit injuria, which states that one who knowingly and voluntarily exposes himself to danger cannot recover damages. However, the Court clarified that even if Mr. Reyes assumed the risk of being asked to leave, petitioners were still obligated under Articles 19 and 21 of the Civil Code to treat him fairly and avoid unnecessary ridicule. The Court found that Ms. Lim's actions did not constitute an abuse of right, thus the doctrine did not preclude recovery in this specific instance because the premise of abuse of right was not met. On the reversal of RTC findings of fact: The Supreme Court held that it could review the findings of fact of the lower courts when they are contradictory, as in this case. The RTC found Ms. Lim's actions discreet, while the CA found them humiliating. After an in-depth review of the evidence, the Supreme Court found the RTC's conclusion more credible. The Court emphasized that Mr. Reyes, as the plaintiff, had the burden of proving his allegations, including the claim that Ms. Lim acted abusively. His failure to provide satisfactory explanations or corroborating witnesses weakened his case. The Court also noted that Dr. Filart, who allegedly invited Mr. Reyes, consistently denied inviting him and did not intervene when he was escorted out, further undermining Mr. Reyes's narrative.
Main Doctrine
The exercise of a legal right, even if seemingly proper, can give rise to liability if done in bad faith or in a manner contrary to morals, good customs, or public policy, causing damage to another. However, the doctrine of volenti non fit injuria may preclude recovery if the injured party knowingly and voluntarily exposed himself to danger. The burden of proof rests on the party alleging abuse of right or bad faith.