GR 209906; (November, 2017) (Digest)
G.R. No. 209906 November 22, 2017
Coca-Cola Bottlers Phils., Inc., Petitioner vs. Ernani Guingona Meñez, Respondent
FACTS
Respondent Ernani Guingona Meñez, a customer at Rosante Bar and Restaurant, ordered a bottle of Sprite. Upon drinking through a straw, he tasted a repulsive substance, later identified as pure kerosene, causing him to vomit and require hospitalization. He filed a complaint for damages against both Rosante and petitioner Coca-Cola Bottlers Phils., Inc. (CCBPI), the manufacturer. The Regional Trial Court (RTC) dismissed the complaint for insufficiency of evidence. On appeal, the Court of Appeals (CA) reversed the RTC, holding CCBPI liable under the doctrine of strict liability for a defective product and awarding moral and exemplary damages, attorney’s fees, and costs to Meñez. CCBPI elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the Court of Appeals erred in holding CCBPI strictly liable for the alleged defective product and in awarding damages, attorney’s fees, and costs to Meñez.
RULING
The Supreme Court granted the petition, reversing the CA and reinstating the RTC’s dismissal of the complaint. The Court held that Meñez failed to prove by preponderance of evidence that CCBPI was the source of the alleged product defect. The doctrine of strict liability in tort for defective products, while persuasive, requires the plaintiff to establish that the defect existed at the time the product left the manufacturer’s control. The evidence presented did not rule out the possibility of tampering at the restaurant level after the bottle left CCBPI’s possession. The chain of custody of the bottle was not clearly established, and the testimony of the chemist who examined the contents was not offered as evidence, rendering the chemical analysis report hearsay. Consequently, Meñez did not successfully prove that the kerosene was in the Sprite bottle when it was manufactured and sealed by CCBPI. Furthermore, the awards for moral and exemplary damages were unjustified absent a clear showing of CCBPI’s liability or any gross negligence. The award of attorney’s fees and costs was also set aside for lack of legal basis under Article 2208 of the Civil Code.