Case Digest (G.R. No. 88561)
Facts:
The case involves Dr. Herman Armovit, his wife Dora Armovit, and their daughter Jacqueline Armovit as petitioners against the Court of Appeals and Northwest Airlines, Inc. as respondents. The events transpired when the Armovit family, residing in the United States, returned to the Philippines for a Christmas visit in October 1981. They purchased three round-trip airline tickets from Northwest Airlines for their journey back to the U.S., with the tickets indicating a departure time of 10:30 A.M. on January 17, 1982, from Manila to Tokyo. On the day of their scheduled flight, the petitioners arrived at the Manila International Airport at 9:15 A.M., well ahead of the indicated departure time. However, they were informed that they could not be accommodated because the flight had already taken off at 9:15 A.M., a discrepancy attributed to an erroneous entry on their tickets. Despite having reconfirmed their reservations prior to departure, the airline failed to correct the erroneo...
Case Digest (G.R. No. 88561)
Facts:
Purchase of Tickets: In October 1981, petitioners Dr. Herman Armovit, Dora Armovit, and Jacqueline Armovit purchased round-trip airline tickets from Northwest Airlines, Inc. for their Christmas visit to the Philippines. The tickets included a return flight from Manila to Tokyo on January 17, 1982, with a departure time of 10:30 A.M. as handwritten by the airline's sales agent.
Reconfirmation of Reservations: Prior to their departure, petitioners reconfirmed their reservations through their representative, Ernesto Madriaga, who presented the tickets at Northwest Airlines' office. The departure time on the tickets remained unchanged, and their names appeared on the passenger manifest as confirmed passengers.
Bumping Off Incident: On January 17, 1982, petitioners arrived at Manila International Airport at 9:15 A.M., one hour and fifteen minutes before the scheduled departure time stated on their tickets. They were informed that Flight 002 had already departed at 9:15 A.M. and that the 10:30 A.M. time on their tickets was erroneous. Petitioners were denied boarding.
Consequences of Bumping Off: Due to the bumping off, Dr. Armovit missed medical appointments in the U.S., and the family suffered anxiety, wounded feelings, and social humiliation. They were accommodated in a hotel and finally boarded a flight on January 18, 1982.
Filing of Complaint: Petitioners filed a complaint for damages in the Regional Trial Court of Manila, alleging breach of contract and seeking compensatory, moral, exemplary, and nominal damages, as well as attorney's fees.
Trial Court Decision: The trial court awarded actual, moral, exemplary, and nominal damages, plus attorney's fees, to the petitioners. Northwest Airlines appealed to the Court of Appeals.
Court of Appeals Decision: The appellate court affirmed the trial court's decision but modified the awards, eliminating moral damages and reducing exemplary damages. It also deleted nominal damages, as actual damages were awarded.
Supreme Court Petition: Both parties elevated the matter to the Supreme Court. Petitioners challenged the deletion of moral damages and the reduction of exemplary damages, while Northwest Airlines sought a review of the appellate court's decision.
Issue:
- Whether petitioners are entitled to moral damages despite not testifying in court.
- Whether the reduction of exemplary damages by the Court of Appeals was proper.
- Whether nominal damages can coexist with actual damages.
Ruling:
The Supreme Court granted the petition and modified the Court of Appeals' decision. It held that:
- Moral Damages: Petitioners are entitled to moral damages despite not testifying in court, as the gross negligence of Northwest Airlines amounted to malice and bad faith. The Court awarded P100,000.00 each to Dr. Herman Armovit, Dora Armovit, and Jacqueline Armovit as moral damages.
- Exemplary Damages: The Court upheld the appellate court's reduction of exemplary damages to P100,000.00 for Dr. Armovit, P50,000.00 for Dora Armovit, and P20,000.00 for Jacqueline Armovit, as these amounts were deemed adequate.
- Nominal Damages: The deletion of nominal damages by the appellate court was proper, as nominal damages cannot coexist with actual damages.
Ratio:
- Moral Damages: Gross negligence by an airline in handling passenger reservations and boarding constitutes malice and bad faith, entitling passengers to moral damages under Article 2220 of the Civil Code. The failure of petitioners to testify in person was sufficiently explained by the political turmoil in the Philippines at the time, and the testimony of Atty. Raymund Armovit adequately established the emotional distress suffered by the petitioners.
- Exemplary Damages: Exemplary damages are awarded to set an example for the public good, especially in cases of gross negligence by common carriers. The amounts awarded by the appellate court were deemed reasonable and proportionate to the actual damages suffered.
- Nominal Damages: Nominal damages are not recoverable when actual damages are awarded, as they serve different purposes. The appellate court correctly deleted the award of nominal damages.
Final Decision
The Supreme Court modified the Court of Appeals' decision and ordered Northwest Airlines to pay:
- Actual damages of P1,300.00 to Dr. Armovit with legal interest from January 17, 1982.
- Moral damages of P100,000.00 and exemplary damages of P100,000.00 to Dr. Armovit.
- Moral damages of P100,000.00 and exemplary damages of P50,000.00 to Dora Armovit.
- Moral damages of P100,000.00 and exemplary damages of P20,000.00 to Jacqueline Armovit.
- Attorney's fees of 5% of the total awards, plus costs of suit.