Case Digest (G.R. No. L-21438) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. L-21438, decided on August 28, 1966 under the 1935 Constitution, Air France (petitioner), through its authorized agent Philippine Air Lines, Inc., issued on March 28, 1958 a first‐class round‐trip ticket from Manila to Rome to respondent Rafael Carrascoso, a civil engineer and member of a Philippine pilgrimage group. Carrascoso duly traveled first class from Manila to Bangkok. Upon boarding the Bangkok–Rome segment, the airline’s Bangkok Manager, alleging a “white man” had “better right” to the seat, forcibly ejected Carrascoso to tourist class despite his confirmed first‐class reservation. Carrascoso protested but complied, endured embarrassment and mental anguish, and purchased an alternative return ticket to Manila. He then filed suit in the Court of First Instance of Manila (Civil Case No. 38810), pleading breach of contract, bad faith, and wrongful expulsion. The trial court awarded him ₱25,000 in moral damages, ₱10,000 in exemplary damages, ₱393.20 (later adjus Case Digest (G.R. No. L-21438) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Context and Ticket Issuance
- Rafael Carrascoso, a civil engineer, was among 48 Filipino pilgrims departing Manila for Lourdes on March 30, 1958.
- On March 28, 1958, he purchased a first-class round-trip airplane ticket Manila–Rome through Philippine Air Lines, Inc., acting as Air France’s agent.
- Travel Experience and Ouster Incident
- Carrascoso traveled first class from Manila to Bangkok. Upon boarding the Bangkok–Rome segment, the Air France manager ordered him to vacate his first-class seat, claiming a “white man” had a superior right.
- Carrascoso refused, a commotion ensued among Filipino passengers, and he was forcibly moved to tourist class against his will.
- Proceedings Below and Awards
- The Court of First Instance of Manila awarded P25,000 moral damages, P10,000 exemplary damages, P393.20 (later reduced) for fare difference, P3,000 attorneys’ fees, legal interest, and costs.
- The Court of Appeals affirmed the judgment in all respects except reducing the fare-difference refund to P383.10, with costs against petitioner.
Issues:
- Adequacy of Findings of Fact
- Did the Court of Appeals fail to state complete findings as constitutionally (Art. VIII, Sec. 12) and statutorily (Rule 51, Sec. 4) required?
- Are appellate findings of fact conclusive in certiorari review, which is limited to questions of law?
- Contractual Right to a First-Class Seat
- Does issuance of a “first class” ticket guarantee a confirmed reservation on each flight segment?
- Can the carrier override the written ticket by an oral reservation-subject-to-availability agreement?
- Award of Moral and Exemplary Damages
- Is bad faith sufficiently averred and proven to justify moral damages in a breach-of-contract action?
- Does the manager’s forceful ejection constitute wanton or oppressive conduct warranting exemplary damages?
- Evidentiary Issues
- Was the passenger’s testimony regarding the purser’s notebook entry admissible under the best-evidence rule?
- Does the res gestae exception admit spontaneous statements made during or immediately after the incident?
- Attorneys’ Fees and Quantum of Awards
- Did the courts below properly exercise discretion in awarding P3,000 attorneys’ fees?
- Are the amounts of moral (P25,000) and exemplary (P10,000) damages reasonable or excessive?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)