Syquia v.

CA & Manila
Memorial Park
Cemetery
G.R. NO. 98695, 27 JANUARY 1993
FACTS:

Petitioners are parents of siblings of deceased Vicente Syquia

who was buried on Manila Memorial Park. The family was
transferring the remains when they discovered a 3-inch hole near
the bottom of the concrete vault encasing the coffin. The coffin
was entirely damaged by water and the body was also covered in
filth and silt.
Petitioners sued for gross negligence and breach of obligation
to deliver a defect free concrete vault.
ISSUE:

Whether or not the petitioner can claim for

damages?
RULING:
The RTC & CA in dismissing the complaint held that because of their pre-existing
contractual relation there can never be quasi-delict. The Supreme Court agrees.
Although a pre-existing contractual relation between the parties does not preclude
the existence of a culpa aquiliana, it finds no reason to disregard the RTC’s finding that
there was no negligence. As testified by the internment foreman, the hole was placed
on the vault so that water could drain when the Syquia was buried because it was
raining that day.
The “Deed of Sale and Certificate of Perpetual Care” governed the relations of the
parties. The agreement provides that the vault must be “sealed”. The Supreme Court
however held that nowhere in the agreement that the vault was to be “waterproof”.
Well settled is the rule that when the terms of the contract are clear and leave no
doubt as to the intention of the contracting parties, then the literal meaning of the
stipulation shall control.