G.R. No. 206306 & G.R. No. 206321, April 03, 2024
MIGUEL KIM, PETITIONER, VS. SLIMMERS WORLD INTERNATIONAL, ALBERT CUESTA, AND DINAH QUINTO, RESPONDENTS. [G.R. No. 206321] SLIMMERS WORLD INTERNATIONAL, ALBERT CUESTA, AND DINAH QUINTO, PETITIONERS, VS. MIGUEL KIM, RESPONDENT.

FACTS

Adelaida Kim, a 59-year-old lifetime member of Slimmers World International (operated by Behavior Modification Inc.), availed of the fitness center’s 12-visit personal training program in June 2000, with Albert Cuesta as her personal trainer. On July 25, 2000, during her 12th and final session, Adelaida completed her workout. While still within the gym premises, she complained of a headache, nausea, and discomfort. The gym staff took her blood pressure, which was high, so she took her hypertension medication. She then vomited while changing. The staff brought her via tricycle to Our Lady of Grace Hospital, where she was diagnosed with essential hypertension. She was later transferred to Chinese General Hospital, where a CT scan revealed a brain mass. She died three days later on July 28, 2000, due to cerebral hemorrhage and severe hypertension. Her husband, Miguel Kim, demanded damages from Slimmers World, its trainer Albert Cuesta, and managing director Dinah Quinto. Upon denial of liability, Miguel filed a complaint for damages. The Regional Trial Court (RTC) found the defendants grossly negligent and jointly and severally liable for damages. The Court of Appeals (CA) affirmed the RTC’s finding of negligence but modified the awards, reducing moral and exemplary damages to PHP 50,000 each and deleting attorney’s fees. Both parties filed petitions for review: Miguel Kim assailed the reduction of damages and deletion of attorney’s fees ( G.R. No. 206306 ), while Slimmers World et al. denied any negligence (G.R. No. 206321).

ISSUE

Whether Slimmers World International, Albert Cuesta, and Dinah Quinto should be held liable for damages resulting from the death of Adelaida Kim.

RULING

No. The Supreme Court reversed the decisions of the lower courts and held that Slimmers World et al. are not liable for damages. The Court found that the proximate cause of Adelaida’s death was her own failure to disclose her pre-existing hypertensive condition, as she answered “no” to a questionnaire asking if she had high blood pressure or hypertension. The fitness center had no duty to constantly monitor the blood pressure of all clients or to have a doctor on standby at all times. The staff exercised the diligence required by the circumstances by immediately responding when Adelaida felt ill, checking her blood pressure, and transporting her to the nearest hospital. The Court ruled that the cause of action, if any, was based on culpa contractual (breach of contract), not quasi-delict. For culpa contractual, the obligor is presumed negligent if guilty of a breach. However, the Court found that Slimmers World did not breach its contractual obligation to provide a safe fitness program. Adelaida’s concealment of her hypertension was a fortuitous event that exempted the obligor from liability under Article 1174 of the Civil Code, as it could not have been foreseen. The awards of damages were set aside.