SC rules client鈥檚 death can鈥檛 be blamed on gym
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MANILA, Philippines — The Supreme Court has absolved a fitness center of liability over the death of its 59-year-old client after a workout session in 2000.
In a decision promulgated on April 3 but made public only on Tuesday, the high tribunal’s First Division ruled that Miguel Kim, the husband of deceased Adelaida Kim, failed to establish that Slimmers World International violated the terms of its contract with his wife and that there was a causal connection between her final training session and death.
The court noted that neither the member’s handout nor the records showed that the gym had an obligation to take the client’s blood pressure and to have a doctor onsite at all times.
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“To be sure, the Court cannot hold the fitness center accountable for terms that do not exist in the contract,” it said in the ruling penned by Associate Justice Jose Midas Marquez.
Article continues after this advertisementThe Supreme Court effectively granted the petition for review on certiorari filed by Slimmers World as it reversed the 2012 decision of the Court of Appeals, which found the gym guilty of breaching its obligation.
Article continues after this advertisementIt also dismissed for lack of merit, Miguel’s complaint for recovery of damages for the death of his wife.
24-year-old case
The case stemmed from a case filed by Miguel in 2000 after his wife died due to cerebral hemorrhage and severe hypertension.
Adelaida, then 59 years old, had availed herself of the 12-visit personal training program of Slimmers World.
Shortly after her 12th session, she complained of a headache and vomited. The gym staff immediately brought her to the hospital but she died after three days.
In a 2009 decision, a local court granted Miguel’s complaint for damages, finding that the gross negligence of Slimmers World, its managing director, and Adelaida’s fitness trainer was the proximate cause of her death.
The gym and its two personnel were ordered to pay a total of P1.3 million in damages and attorney’s fees.
The appellate court affirmed the lower court’s decision in 2012 but reduced the award of moral and exemplary damages from P500,000 and P200,000 to P50,000 each. It also removed the attorney’s fees for “lack of basis.”
Damages reduced
In ruling on the present petition, the Supreme Court said that the gym “can neither be held answerable for contractual negligence nor quasi-delict.”
Quasi-delict is defined as “fault or negligence if there is no pre-existing contractual relation[ship] between the parties.”
The high court underscored that when Adelaida availed herself of the 12-visit program, she “expressly declared” in her application that she was not suffering from hypertension, among others.
“Notably, Adelaida made these declarations despite her duty to ‘inform the Fitness Trainer of any medical problem or concern before engaging in any gym activity,’” the Supreme Court said.
“In the final analysis, while the Court commiserates with Miguel for the death of his wife, it is the solemn duty of this Court to impartially assess the merits of the case on applicable law and evidence adduced,” the court said.
