Nikko Hotel Manila Garden v. Roberto Reyes

Summary

Roberto Reyes sued Hotel Nikko and Ruby Lim for damages, claiming he was humiliated when asked to leave a private birthday party at the hotel's penthouse. The RTC dismissed the case, but the CA reversed, awarding P410,000 in total damages. The Supreme Court reinstated the RTC decision, holding that asking an uninvited guest to leave a private party, when done politely and without abuse, does not constitute a violation of the human relations provisions of the Civil Code. The Court emphasized that claims under Articles 19 and 21 require proof of bad faith or intent to injure, which was not established. The decision clarifies the boundaries of legitimate conduct in private social settings and the requirements for tort liability under the abuse of rights doctrine, rejecting the doctrine of volenti non fit injuria while upholding the right to exclude uninvited guests when done properly.