Spouses Luigi M. Guanio v. Makati Shangri-La Hotel

Summary

The Supreme Court partially reversed the Court of Appeals in this breach of contract case involving a wedding reception at Shangri-La Hotel Makati. While the RTC initially awarded substantial damages based on the hotel's apologetic letter, the CA reversed citing proximate cause. The SC clarified that proximate cause doctrine doesn't apply to contract breaches, which are governed by Civil Code Article 1170. However, the Court found that the contract's exculpatory clause protected the hotel since the couple failed to provide required 48-hour notice of increased guest attendance (470 vs guaranteed 350-380). The hotel's apology letter was deemed standard industry practice, not liability admission. Despite the exculpatory clause, the SC awarded P50,000 nominal damages, recognizing the couple's right to dignity and noting the hotel's imprudent scheduling of concurrent events that contributed to service failures.