Facts:
- Adelaida Kim, wife of Miguel Kim, was a 59-year-old member of Slimmers World fitness center.
- In June 2000, Adelaida availed of a 12-visit personal training program at Slimmers World.
- On July 25, 2000, during her 12th and last session, Adelaida complained of a headache and vomited after her workout.
- The gym staff took her blood pressure, which was high, and brought her to a nearby hospital.
- Three days later, on July 28, 2000, Adelaida died due to cerebral hemorrhage and severe hypertension.
- Miguel Kim filed a complaint for damages against Slimmers World, trainer Albert Cuesta, and managing director Dinah Quinto, alleging their negligence caused his wife’s death.
Issues:
- Whether Slimmers World et al. are liable for contractual negligence
- Whether Slimmers World et al. are liable for quasi-delict under Article 2176 of the Civil Code
Ruling:
The Supreme Court ruled that Slimmers World et al. cannot be held liable for either contractual negligence or quasi-delict:
- On contractual negligence:
- Miguel failed to prove that Slimmers World et al. breached any contractual obligation.
- The contract did not require the fitness center to take Adelaida’s blood pressure before every workout or have a doctor on site at all times.
- Adelaida had declared she was not hypertensive when she availed of the program.
- On quasi-delict:
- Miguel failed to establish the elements of quasi-delict, particularly:
a) The act or omission constituting negligence
b) The causal connection between the act and the damage sustained (proximate cause) - The fitness center took reasonable precautions given the circumstances.
- There was insufficient evidence proving that Adelaida’s workout directly caused her death.
The Court emphasized that while gyms have a duty of care, they are not mandated to guarantee safety from all risks. Miguel failed to discharge his burden of proof in establishing negligence and proximate causation.
The Court therefore granted the petition of Slimmers World et al., reversed the Court of Appeals decision, and dismissed Miguel Kim’s complaint for damages.