G.R. No. 76093 - Air France vs. Court of Appeals

Air France, through its General Sales Agent Aspac Management Corporation in Makati, issued a multi-city airline ticket to private respondent Narciso Morales in October 1977.
The ticket, priced at P9,426.00 plus a travel tax of P1,413.90 (with a partial refund of P413.90), carried specific itinerary segments with restrictions noted as “non endorsable” and “valid on Air France only” on certain flight coupons.

While in New York on November 3, 1977, respondent Morales obtained three medical certificates attesting to an ear infection that required medical attention.
After flying from New York to Paris, Stockholm, and then Copenhagen, respondent requested through petitioner’s office to shorten his itinerary due to his medical condition.
Air France Manila, upon receiving a telex from its Amsterdam office, was asked to reroute the passenger; however, initial and subsequent requests for a revised itinerary (including Hamburg, Paris, Geneva, Rome, Hongkong, and ultimately Manila) were denied based on established ticket restrictions.
As a consequence of the denied rerouting request, respondent purchased a new set of tickets for his return route, incurring an expenditure of 1,914 German marks.

Upon his arrival in Manila, respondent submitted a letter-complaint urging a refund and claiming breach of contract and damages.
The trial court (CFI, Branch 33, Kalookan City) found in respondent’s favor, determining that Air France was in evident bad faith for its handling of the rerouting request and the conduct exhibited by its employees in Hamburg.
The trial court awarded:

The appellate court’s findings were criticized on the basis that the restrictions on the ticket were clearly printed and that the respondent, being a lawyer, should have been aware of these limitations.
The case eventually reached the Supreme Court on a petition for review on certiorari.

Whether Air France, by refusing to reroute respondent Morales as requested, committed a breach of its contract of carriage.

The analysis involves determining if the restricted ticket conditions were clearly stated and binding.
Consideration of the implications of the ticket’s “non endorsable” and “valid on Air France only” markings.

Whether the denial of the rerouting request and the subsequent need for the respondent to purchase new tickets justified the award of actual, moral, and exemplary damages.

Examination of the causal connection between the alleged breach and the damages incurred.
Scrutiny of the medical evidence presented and the consistency of the respondent’s claims regarding his medical condition.

The proper interpretation and application of international and industry standards, including IATA Resolutions (No. 275e and No. 1013), in determining the enforceability of ticket restrictions and the obligations of the carrier.

Analysis of whether the restrictions were adequately communicated to the passenger.
Evaluation of the airline’s procedural adherence in processing changes to the itinerary.