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Syquia V Ca Digested DDDD

- The petitioners filed a complaint against Manila Memorial Park Cemetery for damages arising from breach of contract regarding the sale of a plot of land for their deceased son/brother. - Upon transferring the remains, they discovered a 3-inch hole in the concrete vault containing the coffin, allowing water to leak in and desecrate the grave. - Both the trial court and appellate court ruled in favor of the defendant, finding no guarantee in the contract that the vault would be waterproof, no negligence, and an existing contractual relationship between the parties.

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0% found this document useful (0 votes)
120 views1 page

Syquia V Ca Digested DDDD

- The petitioners filed a complaint against Manila Memorial Park Cemetery for damages arising from breach of contract regarding the sale of a plot of land for their deceased son/brother. - Upon transferring the remains, they discovered a 3-inch hole in the concrete vault containing the coffin, allowing water to leak in and desecrate the grave. - Both the trial court and appellate court ruled in favor of the defendant, finding no guarantee in the contract that the vault would be waterproof, no negligence, and an existing contractual relationship between the parties.

Uploaded by

Vincent Bernardo
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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petitioners, Juan J. Syquia and Corazon C. Syquia, Carlota C. Syquia, Carlos C.

Syquia, and Anthony


Syquia, were the parents and siblings, respectively, of the deceased Vicente Juan Syquia. On March 5,
1979, they filed a complaint [1] in the then Court of First Instance against herein private respondent,
Manila Memorial Park Cemetery, Inc. for recovery of damages arising from breach of contract and/or
quasi-delict. The trial court dismissed the complaint.

-Plaintiff and defendant entered into a contract of sale for a plot of land wherein the deceased
son/brother of the petitioners was to be transferred.

-upon the transfer of the remains they were surprised to see a hole 3 inches of diameter in the concrete
vault in one of the holes of the niche causing water to leak and causing ill effects to the deceased and
the coffin. Due to the alleged unlawful and malicious breach by the defendant-appellee of its obligation
to deliver a defect-free concrete vault designed to protect the remains of the deceased and the coffin
against the elements which resulted in the desecration of deceased’s grave.

RTC - the trial court held that the contract between the parties did not guarantee that the cement vault
would be waterproof; that there could be no quasi-delict because the defendant was not guilty of any
fault or negligence, and because there was a preexisting contractual relation between the Syquias and
defendant Manila Memorial Park Cemetery, Inc..

the Syquias appealed. They alleged that the trial court erred in holding that the contract allowed the
flooding of the vault; that there was no desecration; that the boring of the hole was justifiable; and in
not awarding damages.

CA affirmed the ruling of the RTC

ISSUE: WON THERE WAS NEGLIGENCE ON THE PART OF THE RESPONDENT WHICH RESULTED TO BRACH
OF CONTRACT

HELD: There is not enough ground, both in fact and in law, to justify a reversal of the decision of the
respondent Court and to uphold the pleas of the petitioners. had there been

actual negligence on the part of the Manila Memorial Park Cemetery, Inc., it would

be held liable not for a quasi-delict or culpa aquiliana, but for culpa contractual as provided by Article
1170 of the Civil Code, to wit: “Those who in the performance of their obligations are guilty of fraud,
negligence, or delay, and those who in any manner contravene the tenor thereof, are liable for
damages.”

There was no stipulation in the Deed of Sale and Certificate of Perpetual Care and in the Rules and
Regulations of the Manila Memorial Park Cemetery, Inc. that the vault would be waterproof. Private
respondent’s witness, Mr. Dexter Heuschkel, explained that the term “sealed” meant “closed.”

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