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...

Facts:

Background of the Case

• The petitioners – Dr. Herman Armovit, Mrs. Dora Armovit, and Miss Jacqueline Armovit – are Filipino residents residing in the United States who intended to spend their Christmas holidays in the Philippines.
• They purchased three round-trip airline tickets from private respondent Northwest Airlines, Inc., which also involved additional tickets for other family members not included in the suit.
• Each ticket, handwritten by the airline’s ticket sales agent, contained an entry for the segment “Manila to Tokyo” stating: “from Manila to Tokyo, NW flight 002, date 17 January, time 10:30 A.M. Status, OK.”

Erroneous Entry and Its Immediate Repercussions

• Upon their return from the Philippines on January 17, 1982, the petitioners arrived at the Manila International Airport’s check-in counter at 9:15 A.M., well in advance of the indicated departure time.
• At check-in, they were informed—quite rudely—that they could not be accommodated because the ticket stated a departure time of 10:30 A.M. and that the flight scheduled at 9:15 A.M. had already taken off.
• Prior to the departure date, the petitioners had re-confirmed their reservations through their representative, Ernesto Madriaga, who personally presented the same set of tickets at the airline’s Roxas Boulevard office without any correction to the erroneous departure time.
• Their names were duly noted in the passenger manifest as Passenger Nos. 306, 307, and 308 on Flight 002.

Consequences and Subsequent Actions

• The bump-off caused the petitioners significant inconvenience: Dr. Armovit was unable to keep his U.S. appointments, and all petitioners experienced severe anxiety, wounded feelings, and social humiliation.
• During the delay until January 18, 1982—the day they were assured seats on a later flight—the petitioners incurred additional expenses, for instance, spending P1,300.00 on meals while in hotel accommodations arranged by the airline.
• Due to the respondent’s refusal to pay compensatory damages for the perceived breach of the air transportation contract, the petitioners filed an action for damages in the Regional Trial Court of Manila.

Trial Court Decision and Award of Damages

• The trial court rendered a decision on July 2, 1985, awarding:
• Actual damages of P1,300.00 (with interest from January 17, 1982) to Dr. Armovit.
• Moral, exemplary, and nominal damages in various amounts against Northwest Airlines for each petitioner (with differing awards for Dr. Herman, Mrs. Dora, and Miss Jacqueline Armovit).
• Attorney’s fees amounting to 5% of the total damages awarded, plus the costs of the suit.

Appellate Court Ruling and Modifications

• On appeal, the Court of Appeals held that although the petitioners had complied with the 72-hour reconfirmation rule, the airline was grossly negligent by failing to correct the erroneous ticket entry.
• The appellate court maintained Dr. Armovit’s actual damages but modified the award as follows:
• It eliminated moral damages on the ground that the petitioners did not personally testify about their social humiliation and anxiety and that the breach was not deemed malicious or fraudulent.
• It reduced the exemplary damage awards considerably for each petitioner and eliminated nominal damages on the basis that they could not exist alongside actual damages.
• The petitioners then filed a motion for reconsideration, which was denied on May 29, 1989, prompting both parties to elevate the matter to the Supreme Court by certiorari.

Supreme Court’s Involvement

• The Supreme Court, after reviewing the case on certiorari and the appealed decisions, found that the airline’s act of issuing erroneous tickets (and the neglect to correct them upon reconfirmation) amounted to gross negligence, bordering on malice and bad faith.
• Citing relevant precedents—including Air France vs. Carrascoso, Lopez vs. Pan American World Airways, and Zulueta vs. Pan American World Airways—the Court underscored the high duty of care owed by air carriers to their passengers.
• Evidence, including the detailed testimony by Atty. Raymund Armovit, established the extent of the petitioners’ anxiety, social humiliation, and wounded feelings resulting from their treatment.
• Consequently, the Supreme Court modified the Court of Appeals’ decision: it reinstated and affirmed the award of moral damages (P100,000.00 each), confirmed exemplary damages (with specific amounts for each petitioner), and maintained the actual damages along with attorney’s fees.

Issue:

Existence of a Breach of the Air Transportation Contract

• Whether the erroneous entry in the tickets constituted a breach of the contractual obligation of care expected from the airline.
• Whether the airline’s negligence in issuing and reconfirming the erroneous tickets could be equated with, or amount to, gross negligence involving malice or bad faith.

Entitlement to Damages

• Whether the petitioners were entitled to actual damages based on the tangible losses they incurred.
• Whether the additional claims for moral and exemplary damages were justified given the nature of the breach and its consequences.
• Whether the failure of the petitioners to testify in person regarding their social humiliation, wounded feelings, and anxiety could justify the elimination of moral damages.

Judicial Discretion and the Question of Award Amounts

• Whether the appellate court had the proper authority to modify or drastically reduce the amounts of exemplary damages initially granted by the trial court.
• Whether nominal damages should be awarded concurrently with actual damages under the established doctrine.

Public Policy Considerations

• Whether the corrective and deterrent purpose of awarding exemplary damages in cases of gross negligence by air carriers should influence the final quantum of damages.
• Whether the interests of public welfare and the maintenance of proper airline standards justify the punitive elements embedded in the award.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)