G.R. No. 154259; February 28, 2005
NIKKO HOTEL MANILA GARDEN and RUBY LIM, petitioners, vs. ROBERTO REYES, a.k.a. “AMAY BISAYA,” respondent.

FACTS

Respondent Roberto Reyes, a television personality known as “Amay Bisaya,” attended a private birthday party at the penthouse of petitioner Nikko Hotel Manila Garden on October 13, 1994. Reyes claimed he was invited by his friend, Dr. Violeta Filart, a guest. While lining up for the buffet dinner, petitioner Ruby Lim, the hotel’s Executive Secretary and party organizer, allegedly told him in a loud and humiliating manner to leave because he was not invited. Reyes further claimed he was later escorted out by a policeman, causing him shock, shame, and embarrassment, for which he sought damages.
Petitioners presented a contrary version. They asserted the party was exclusive, with a limited guest list that did not include Reyes. Ruby Lim testified that upon noticing the uninvited Reyes, she discreetly made several attempts, through intermediaries, to ask him to leave. Only after he lingered and began eating did she personally approach him, and she did so politely. She claimed it was Reyes who then created a scene. Dr. Filart also denied inviting Reyes.

ISSUE

Whether petitioners Nikko Hotel Manila Garden and Ruby Lim are liable for damages under Articles 19, 20, and 21 of the Civil Code for the manner in which they asked an uninvited guest to leave a private party.

RULING

The Supreme Court ruled in favor of the petitioners and reversed the Court of Appeals. The Court held that petitioners are not liable for damages. The legal logic is anchored on the absence of actionable fault or negligence. While Reyes suffered humiliation, the evidence established that Ruby Lim acted with discretion and propriety in safeguarding the private, exclusive nature of the event. She initially sought the assistance of others to avoid a direct confrontation and only spoke to Reyes directly when other measures failed, doing so in a courteous manner.
The Court emphasized that the right to privacy of the celebrant and the organizer’s duty to maintain the party’s intimate character are legally recognized. Reyes, being an uninvited guest, assumed the risk of being asked to depart. His mere subjective feeling of embarrassment does not automatically translate to a legal wrong warranting damages, especially when the act of asking him to leave was exercised in a lawful and non-abusive manner. There was no showing of willful intent to injure or of negligent conduct contrary to law, which are essential elements for liability under the human relations provisions of the Civil Code. Therefore, no legal basis for an award of damages exists.