SYQUIA v COURT OF APPEALS length of time (one hour, estimated),

GR No 98695 | January 27, 1993 water drained out of the hole.

Created by: Migs Gayares  Due to the discovery, plaintiffs became
agitated and upset due to the water that
TOPIC: had collected inside the vault, which
Obligations; General Provisions; Nature and might have risen to the level of the
Effect of Obligations. coffin and flooded the same as well as
the remains of the deceased with ill
PETITIONERS: effects.
Juan Syquia, Corazon Syquia, Carlota Syquia,  Pursuant to an authority granted by the
Carlos Syquia, and Anthony Syquia Municipal Court of Parañaque on
September 14, 1978, plaintiffs with the
RESPONDENTS: assistance of licensed morticians and
Court of Appeals and the Manila Memorial Park the personnel of MMPC opened the
Cemetery, Inc. (MMPC) concrete vault and discovered evidence
of total flooding:
DOCTRINE: a. Interior walls of the concrete
The rule is clear that when the terms of the vault were damaged by
contract are clear and leave no doubt as to the flooding;
intention of the contracting parties, then the b. Coffin was entirely damaged
literal meaning of the stipulation shall control. by water, filth, and slit causing
Contracts are interpreted in their literal meaning the wooden parts to warp and
and not beyond their obvious intendment. separate and to crack the
viewing glass panel located
above the head and torso of the
FACTS: deceased;
 Petitioners (Syquias) were the parents c. Entire lining of the coffin,
and siblings of the deceased, Vicente clothing of the deceased, and
Juan Syquia. They filed a complaint on the exposed parts of the
against private respondent, MMPC, for deceased’s remains were
recovery of damages arising from damaged due to the flooding
breach of contract and/or quasi-delict. and the silt were also coated
The trial court dismissed the complaint. with filth.
 The complaint alleged that pursuant to a  Due to the alleged unlawful and
Deed of Sale and Interment Order malicious breach by the MMPC of its
executed between the plaintiff-appellant obligation to deliver a defect-free
Juan Syquia, father of the deceased concrete vault designed to protect the
Vicente Syquia, and defendant-appellee, remains of the deceased and the coffin
the former instructed the latter to inter against elements which resulted in the
the remains of the deceased in the desecration of the deceased’s remains
Manila Memorial Park Cemetery in the and due to MMPC’s gross negligence
morning of July 25, 1978 in accordance conformably to Article 2176 of the
with the latter’s interment procedures. Civil Code in failing to seal the concrete
 That on September 4, 1978, in vault, the plaintiff prayed that judgment
preparation for the transfer of the be rendered ordering MMPC to pay
remains to a newly purchased plot also P30k for actual damages, P500k for
in the same cemetery, the concrete vault moral damages, exemplary damages in
encasing the coffin of the deceased was the amount determined by court, 20% of
removed from its underground niche by MMPC’s total liability as attorney’s
the employees of MMPC. That as the fees, and litigation expenses.
concrete vault was raised to the surface,  RTC: Complaint dismissed since the
plaintiffs discovered a hole contract between the parties did not
approximately 3 inches in diameter near guarantee that the cement vault would
the bottom of the walls closing out the be waterproof; that there could be no
width of the vault and that for a certain quasi-delict because the defendant was
 not guilty of any fault or negligence and
because there was a pre-existing MMPC served its obligations to the Syquias but
contractual relation between the the latter claims that they breached its contract
Syquias and MMPC. Court also notes since what was advertised in the brochure they
that the father, Juan Syquia, chose the held out was that underground internment was
gravesite despite knowledge that said done in a sealed concrete vault. The Syquias
area had to be constantly sprinkled with claim that the vault provided was not sealed, not
water to keep the grass green and that waterproofed, hence, water seeped through the
water would eventually seep through cement enclosure and damaged everything. The
the vault. The Court also accepts the Court does not agree since there was no
explanation given by the defendant for stipulation in their contract and in the Rules and
the purpose of the hole, which helped in Regulations of the MMPC that the vault would
draining the water from the vault. be waterproof. MMPC’s witness, Dexter
 CA: Affirmed the judgment of the Heuschkel, explained that “sealed” meant
case’s dismissal. Motion for “closed.” Sealed cannot be equated with
reconsideration was also denied. waterproof.

ISSUE: The rule is clear that when the terms of the

W/N the act of boring a hole by MMPC on the contract are clear and leave no doubt as to the
vault of the deceased was a breach of the intention of the contracting parties, then the
contractual obligation to provide a sealed vault, literal meaning of the stipulation shall control.
which would constitute a negligent act leading to Contracts are interpreted in their literal meaning
a quasi-delict? and not beyond their obvious intendment.

HELD: MMPC did not breach the tenor of its obligation

NO – The Court empathizes with the plaintiffs; to the Syquias. As for the hole in the coffin, the
however, there is not enough ground, both in fact Court ruled that the circumstances surrounding
and in law, to justify a reversal of the decision by the commission of such act negated the
the lower courts and to uphold the pleas of the allegation of negligence as the Interment
petitioners. Foreman explained it. MMPC exercised the
diligence of a good father in preventing the
RATIO: accumulation of water inside the vault, which
CA found no negligent act on the part of MMPC would have resulted in the caving in of earth
to justify an award of damages against it. around the grave.
Although a pre-existing contractual relation
between the parties does not preclude the No reason to award damages in favor of
existence of a culpa aquiliana, the Court finds no petitioners.
reason to disregard the finding that there was no
negligent act committed in the case. KWENTO:
The son of the Syquias died and he was buried in
Art. 2176 – Whoever by act or omission causes MMPC through their own services. They
damage to another, there being fault or transferred the body and discovered that the
negligence, is obliged to pay for the damage vault was flooded and that the flooding damaged
done. Such fault or negligence, if there is no pre- everything. Syquias accused MMPC of
existing contractual relation between the parties, breaching the contract since they promised a
is called a quasi-delict. “sealed” coffin. RTC, CA, and SC denied the
Syquia’s claim since “sealed” is not the same as
In this case, the Syquias and MMPC entered into “waterproofed.” Contracts must be interpreted in
a contract entitled “Deed of Sale and Certificate their literal meaning.
of Perpetual Care” on August 27, 1969. The
agreement covered the relationship of the parties
and their rights and obligations. Hence, had there
been negligence on MMPC’s side, it would be
held liable NOT for a quasi-delict or culpa
aquiliana, but for culpa contractual as provided
by Art. 1170 of the Civil Code.