Case Digest (G.R. No. 182395)
Facts:
- Marito T. Bernales, a lawyer and university dean, filed a complaint against Northwest Airlines (NWA) for breach of contract.
- Bernales was part of a trade and tourism mission traveling to Honolulu, Hawaii, on October 1, 2002, via NWA Flight No. 10 from Manila to Honolulu through Narita, Japan.
- Upon arrival at Narita International Airport around 11:00 a.m., a typhoon hit Japan at around 6:00 p.m., causing the cancellation of most flights, including NWA Flight No. 10.
- NWA did not cancel Flight No. 22, also bound for Honolulu, to accommodate stranded passengers if the typhoon subsided.
- The airport resumed operations at around 9:00 p.m., and the Narita Airport Authority extended the curfew to 1:00 a.m. to accommodate delayed flights.
- Bernales and his group opted to be wait-listed for Flight No. 22, but Bernales was placed last on the wait-list and given a "dummy" boarding pass.
- NWA Customer Service Agent Tsuruki Ohashi informed Bernales that no seat was available for him, leading to a disputed altercation.
- Bernales was eventually transported to the airplane, but Flight No. 22 did not depart before the curfew, and passengers spent the night at the airport.
- Bernales filed a complaint for moral and exemplary damages, which the Regional Trial Court (RTC) of Iriga City, Branch 60, granted, awarding him P12,530,000.00.
- NWA appealed, and the Court of Appeals (CA) reversed the RTC decision, dismissing the complaint.
- Bernales filed a petition for review on certiorari with the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that Northwest Airlines did not act in bad faith and therefore, moral and exemplary damages were not warranted.
- The Supreme Court held that the typhoon was a fortuitous...(Unlock)
Ratio:
- Moral damages in breaches of contracts of carriage are only recoverable when the mishap results in death or where the carrier is guilty of fraud or bad faith.
- Bad faith involves ill intentions and a conscious design to do a wrongful act for a dishonest purpose.
- The primary cause of NWA's delay was the unusually strong Typhoon Higos, leading to widespread flight cancellations.
- NWA attempted to accommodate the delayed passengers on a later flight, but the mandatory airp...continue reading
Case Digest (G.R. No. 182395)
Facts:
The case of "Bernales v. Northwest Airlines" involves the petitioner, Marito T. Bernales, a lawyer, university dean, and board member of the Sangguniang Panlalawigan of Camarines Sur, who filed a complaint against Northwest Airlines (NWA) for breach of contract. On October 1, 2002, Bernales and other prominent personalities from Bicol were traveling to Honolulu, Hawaii, as delegates of a trade and tourism mission. They were economy class passengers on NWA Flight No. 10 from Manila to Honolulu via Narita, Japan. Upon arrival at Narita International Airport at around 11:00 a.m., a typhoon hit Japan at around 6:00 p.m., leading to the cancellation of most flights, including NWA Flight No. 10. NWA did not cancel Flight No. 22, also bound for Honolulu, to accommodate stranded passengers if the typhoon subsided. The airport resumed operations at around 9:00 p.m., and the Narita Airport Authority extended the curfew to 1:00 a.m. to accommodate delayed flights. Bernales and his group opted to be wait-listed for Flight No. 22, but Bernales was placed last on the wait-list. NWA issued "dummy" boarding passes to wait-listed passengers, including Bernales. However, before the shuttle bus could leave, NWA Customer Service Agent Tsuruki Ohashi informed Bernales that no seat was available for him. Bernales claimed that Ohashi rudely ejected him from the shuttle, but NWA contended that Ohashi politely asked him to alight. Eventually, Bernales was transported to the airplane, but Flight No. 22 failed to depart ...