Case Digest (G.R. No. L-21438) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Air France vs. Carrascoso (G.R. No. L-21438, decision dated September 28, 1966 under the 1935 Constitution), petitioner Air France, through its agent Philippine Air Lines, issued respondent Rafael Carrascoso a confirmed first class round-trip ticket from Manila to Rome via Bangkok and other intermediate points. Carrascoso, a civil engineer, traveled first-class from Manila to Bangkok, where the airline’s Bangkok manager insisted that he vacate his seat in favor of a white passenger, despite his confirmed reservation. A commotion ensued, and Carrascoso, though reluctant, was forcibly moved to tourist class. He completed his trip on another carrier to avoid further embarrassment. In the Court of First Instance of Manila (Civil Case No. 38810), the trial court found a breach of contract in bad faith and awarded Carrascoso ₱25,000 moral damages, ₱10,000 exemplary damages, ₱393.20 as fare difference (later reduced to ₱383.10 by the Court of Appeals), ₱3,000 attorneys’ fees, intere Case Digest (G.R. No. L-21438) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Prior Proceedings
- Petitioner Air France, through its agent Philippine Air Lines, issued respondent Rafael Carrascoso a “first class” round‐trip ticket Manila–Rome on March 28, 1958.
- Carrascoso traveled first‐class from Manila to Bangkok. At Bangkok he was ordered by the airline manager to vacate his first‐class seat in favor of a “white man” and, after protest and commotion, reluctantly complied.
- Trial Court and Court of Appeals Decisions
- The Court of First Instance of Manila awarded Carrascoso:
- ₱25,000 moral damages;
- ₱10,000 exemplary damages;
- ₱393.20 fare difference;
- ₱3,000 attorneys’ fees; and costs, all with legal interest.
- The Court of Appeals affirmed in all respects except it reduced the fare‐difference award to ₱383.10.
Issues:
- Completeness of Appellate Findings
- Whether the Court of Appeals failed to state “complete findings of fact on all issues” as required by Constitution and Rules.
- Whether this Court on certiorari may review or alter those factual findings.
- Contractual Entitlement to First‐Class Accommodation
- Whether issuance of a first‐class ticket without explicit reservations guarantees the passenger a first‐class seat on every flight segment.
- Whether petitioner may invoke ticket‐availability or verbal side‐agreements to deny first‐class service.
- Damages for Breach and Tortious Ouster
- Whether Carrascoso’s cause of action, based on breach of contract, supports moral damages absent explicit averment of bad faith.
- Whether the ouster from the seat and attendant humiliations suffice to prove bad faith and warrant moral, exemplary damages, and attorneys’ fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)