GR 98695; (January, 1993) (Digest)
G.R. No. 98695 January 27, 1993
JUAN J. SYQUIA, CORAZON C. SYQUIA, CARLOTA C. SYQUIA, CARLOS C. SYQUIA and ANTHONY C. SYQUIA, petitioners, vs. THE HONORABLE COURT OF APPEALS, and THE MANILA MEMORIAL PARK CEMETERY, INC., respondents.
FACTS
Petitioners, the parents and siblings of the deceased Vicente Juan Syquia, filed a complaint for damages against private respondent Manila Memorial Park Cemetery, Inc. The complaint arose from the discovery on September 4, 1978, while transferring the deceased’s remains to a new family plot, that the concrete vault encasing the coffin had a hole approximately three inches in diameter. Water drained from this hole, and upon opening the vault on September 15, 1978, they found the interior walls showed evidence of total flooding, the coffin was damaged by water, filth, and silt, and the deceased’s remains and clothing were soiled. Petitioners alleged this constituted a breach of contract, as the respondent’s brochure stated interments were in “sealed concrete vaults,” and/or gross negligence (quasi-delict) resulting in desecration. The trial court dismissed the complaint, a decision affirmed by the Court of Appeals.
ISSUE
Whether the Manila Memorial Park Cemetery, Inc. is liable for damages due to (1) breach of contract (culpa contractual) for failing to provide a sealed, waterproof vault, or (2) negligence constituting a quasi-delict (culpa aquiliana).
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision, finding no liability on the part of the private respondent.
1. On Breach of Contract (Culpa Contractual): The Court held there was no breach. The contract between the parties, the “Deed of Sale and Certificate of Perpetual Care” and its attached Rules and Regulations, only obligated the respondent to provide a concrete vault for interment (Rule 17). There was no stipulation that the vault would be “waterproof.” The term “sealed” in the brochure was interpreted to mean “closed” or a fastening that prevents unauthorized opening, not that it was impervious to water. Contracts are interpreted according to their literal meaning, and the parties are bound by their terms.
2. On Quasi-Delict (Culpa Aquiliana): The Court found no negligence. While a pre-existing contract does not preclude a quasi-delict claim, the evidence showed the respondent exercised the diligence of a good father of a family. The act of boring a hole in the vault was justified by the respondent’s interment foreman, who explained it was necessary to prevent the vault from floating during heavy rain, which would cause the surrounding earth to cave in and fill the grave. The Court found this explanation reasonable and negated any allegation of fault or negligence.
Since there was no breach of contract and no negligent act, the Court found no ground to award actual, moral, or exemplary damages to the petitioners.