G.R. No. 228150 . January 11, 2023
Karlos Noel R. Aleta, Petitioner, vs. Sofitel Philippine Plaza Manila, Respondent.

FACTS

On February 13, 2009, the parents-in-law of petitioner Karlos Noel R. Aleta, accompanied by his two young children, Carlos and Mario, went to respondent Sofitel Philippine Plaza Manila. The children, aged five and three, were brought to the hotel’s kiddie pool. Mario slipped while stepping into the pool near the lifeguard station, hitting his head on the rugged edge, causing it to bleed. Carlos, while using the kiddie pool slide, bumped his head, sustaining a contusion and bleeding. First aid was administered, and the children were treated at the hotel clinic. In June 2009, Carlos began having seizures, leading to hospitalization and medical expenses. Karlos filed a Complaint for Damages against Sofitel before the Metropolitan Trial Court, alleging negligence due to the pool’s non-visible steps, jagged edges, obscured warning signs, accessible slide steps without barriers, and inattentive lifeguards. The Metropolitan Trial Court dismissed the complaint, finding Karlos failed to prove proximate cause and noting the children were not registered guests on the incident date. The Regional Trial Court and the Court of Appeals affirmed the dismissal, ruling Karlos failed to establish a causal connection between Sofitel’s alleged negligence and the injuries.

ISSUE

Whether or not respondent Sofitel Philippine Plaza Manila should be held liable for the injuries sustained by petitioner Karlos Noel R. Aleta’s children.

RULING

No. The Supreme Court denied the petition and affirmed the lower courts’ decisions. The Court held that the determination of negligence is a question of fact, and in a Petition for Review under Rule 45, its jurisdiction is generally limited to reviewing errors of law. While exceptions exist, such as a gross misapprehension of facts constituting grave abuse of discretion, the petitioner failed to demonstrate that the Court of Appeals committed such. To sustain a claim based on quasi-delict under Article 2176 of the Civil Code, the plaintiff must prove: (1) fault or negligence of the defendant; (2) damage suffered by the plaintiff; and (3) a causal connection between the negligence and the damage. The Court found that the petitioner failed to discharge the burden of proving these elements by preponderance of evidence. Specifically, he did not sufficiently establish that the respondent’s alleged negligence was the proximate cause of his children’s injuries. The petition was unmeritorious.