Michael Ortega Ligalig

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  • Miguel Kim v. Slimmers World International, Albert Cuesta, and Dinah Quinto (G.R. No. 206306 & G.R. No. 206321)

    Miguel Kim v. Slimmers World International, Albert Cuesta, and Dinah Quinto (G.R. No. 206306 & G.R. No. 206321)

    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:

    1. Whether Slimmers World et al. are liable for contractual negligence
    2. 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:

    1. 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.
    1. 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.

  • San Miguel Foods, Inc. v. Spouses Ramon and Ma. Nelia Fabie, and Fresh Link, Inc.

    San Miguel Foods, Inc. v. Spouses Ramon and Ma. Nelia Fabie, and Fresh Link, Inc.

    Case Title:

    G.R. No.: 234849

    Date: June 30, 2024

    Ponente: Justice Hernando

    Facts:

    • Fresh Link, Inc., owned by Spouses Ramon and Nelia Fabie, entered into a Complementary Distributorship Agreement with San Miguel Foods, Inc. (SMFI) in 1992, which was renewed yearly.
    • In April 1999, the agreement was renewed again to expire on March 31, 2000.
    • On June 4, 1999, SMFI ceased delivery of products on credit to Fresh Link.
    • Fresh Link filed a complaint against SMFI for breach of contract and damages, alleging SMFI unilaterally terminated the agreement.
    • SMFI claimed Fresh Link had unpaid accounts and its letter of credit had expired.
    • The RTC ruled in favor of Fresh Link and awarded damages. The Court of Appeals affirmed with modifications.

    Issues:

    1. Whether SMFI is entitled to its counterclaims
    2. Whether SMFI unilaterally terminated the agreement with Fresh Link
    3. Whether respondents are entitled to damages

    Ruling:

    1. SMFI is not entitled to its counterclaims. The documents submitted were mere photocopies, inadmissible under the best evidence rule.
    2. Respondents failed to prove by preponderance of evidence that SMFI unilaterally terminated the agreement. Evidence showed SMFI only denied credit purchases, not terminated the agreement entirely.
    3. Respondents are not entitled to damages. They failed to sufficiently prove SMFI’s alleged breaches of contract beyond Nelia Fabie’s testimony and complaint letters.

    The Supreme Court reversed the CA decision and dismissed Fresh Link’s complaint for lack of merit.

    Dispositive Portion:
    The Petition is GRANTED. The May 18, 2017 Decision and October 18, 2017 Resolution of the Court of Appeals are REVERSED and SET ASIDE. The Complaint filed by respondents is DISMISSED for lack of merit.