Nikko Hotel v. Reyes

G.R. No. 154259 (February 28, 2005)

SC upheld dismissal of Reyes' complaint; Lim's actions deemed justified, not malicious.

Facts:

The case involves a dispute between Roberto Reyes, also known as "Amay Bisaya," and Nikko Hotel Manila Garden, represented by Ruby Lim, the hotel's Executive Secretary. The incident occurred on October 13, 1994, during a private birthday party for the hotel manager, Mr. Masakazu Tsuruoka. Reyes was invited to the hotel by his friend, Dr. Violeta Filart, who allegedly invited him to join her at the party. Upon arriving at the penthouse, Reyes was initially welcomed but later faced humiliation when Ruby Lim confronted him at the buffet table.

Lim, acting on behalf of the hotel, publicly ordered Reyes to leave the party, stating he was not invited. This confrontation occurred in front of other guests, leading to Reyes feeling embarrassed and ashamed. Despite his attempts to explain that he was invited by Dr. Filart, she did not support him, further exacerbating his humiliation. Following this, a policeman escorted Reyes out of the hotel, which he described as a traumatic experience.

Reyes subsequently filed a complaint for damages against Lim and the hotel, claiming actual damages, moral damages, and attorney's fees. Lim admitted to asking Reyes to leave but denied doing so in a loud or humiliating manner. She argued that Reyes was not on the guest list and that her actions were necessary to maintain the exclusivity of the event.

The Regional Trial Court (RTC) initially dismissed Reyes's complaint, finding that he had assumed the risk of being asked to leave since he was uninvited. However, upon appeal, the Court of Appeals reversed this decision, ruling that Lim's actions were contrary to morals and good customs, thus making her liable for damages.

Legal Issues:

  1. Whether Ruby Lim acted abusively in asking Roberto Reyes to leave the party, thereby incurring liability under Articles 19 and 21 of the Civil Code.
  2. Whether Hotel Nikko, as Lim's employer, is solidarily liable for her actions.
  3. The applicability of the doctrine of "volenti non fit injuria" (to which a person assents is not esteemed in law as injury) in this case.

Arguments:

  • Petitioners (Nikko Hotel and Ruby Lim):

    • They contended that Reyes was a "gate-crasher" and assumed the risk of being embarrassed by attending an event to which he was not invited.
    • They argued that Lim's actions were within her rights as the event organizer and did not constitute an abuse of rights.
    • They asserted that the Court of Appeals erred in its findings and that Lim's conduct did not meet the threshold for liability under Articles 19 and 21.

  • Respondent (Roberto Reyes):

    • Reyes argued that Lim's public confrontation was humiliating and constituted an act contrary to morals and good customs, warranting compensation for damages.
    • He maintained that Lim's actions were not justified, as she could have approached him discreetly or verified his invitation with Dr. Filart before confronting him.
    • Reyes claimed that the embarrassment he suffered was exacerbated by the manner in which he was asked to leave, which was loud and public.

Court's Decision and Legal Reasoning:

The Supreme Court ultimately ruled in favor of Nikko Hotel and Ruby Lim, reversing the Court of Appeals' decision. The Court found that the RTC's assessment of the facts was more credible, particularly regarding the manner in which Lim asked Reyes to leave. The Court emphasized that Lim's request was made discreetly and was not intended to cause embarrassment.

The Court highlighted the following points in its reasoning:

  • The doctrine of "volenti non fit injuria" was applicable, as Reyes voluntarily attended a private event without an invitation, thus assuming the risk of being asked to leave.
  • Lim's actions did not constitute an abuse of rights under Articles 19 and 21 of the Civil Code, as she acted within her authority and did not exhibit malice or intent to humiliate Reyes.
  • The Court noted that Reyes failed to provide sufficient evidence to support his claims of humiliation and embarrassment, particularly as he did not present witnesses to corroborate his version of events.

The Court concluded that Lim's conduct was appropriate given the circumstances, and as such, neither she nor Hotel Nikko could be held liable for damages.

Significant Legal Principles Established:

  • The case reaffirms the principle that individuals attending private events must respect the host's rights and the exclusivity of such gatherings.
  • It clarifies the application of Articles 19 and 21 of the Civil Code concerning the exercise of rights and the standards of conduct expected in social interactions.
  • The ruling underscores the importance of evidence in civil cases, particularly the burden of proof resting on the party making allegations of wrongdoing.