Case Digest (G.R. No. 150843) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Cathay Pacific Airways, Ltd. (hereinafter Cathay) is a common carrier operating the Manila–Hong Kong–Manila route and maintains a Marco Polo Club loyalty program granting priority upgrades to frequent flyers. On 28 September 1996, Dr. Daniel Earnshaw Vazquez and Maria Luisa Madrigal Vazquez (hereinafter the Vazquezes), both Gold Card members, checked in for Flight CX-905 in Business Class along with two friends and a maid. At boarding, ground personnel notified the Vazquezes of an involuntary upgrade to First Class due to overbooking of Business Class. The Vazquezes initially refused—citing their role as hosts and the need to confer with their guests—yet were told that refusal would bar them from flying. Reluctantly they accepted the First Class seats. Upon return, the Vazquezes demanded ₱1 million in damages for humiliation and embarrassment and a written apology within fifteen days. After Cathay’s failure to respond substantively, the Vazquezes filed suit in the Makati RTC on Case Digest (G.R. No. 150843) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Cathay Pacific Airways, Ltd. (Cathay) – common carrier; frequent‐flyers enjoy Marco Polo Club privileges, including priority upgrading to higher class when opportunity arises.
- Spouses Daniel Earnshaw Vazquez and Maria Luisa Madrigal Vazquez – Gold Card members of Marco Polo Club; traveled with two friends and a maid to Hong Kong on 24 September 1996.
- Booking and Check‐In
- Return Flight CX‐905 (Hong Kong to Manila) scheduled 28 September 1996 at 9:20 p.m.; Vazquezes and friends booked Business Class, maid in Economy.
- Two hours before departure, passengers checked in at Kai Tak Airport; boarding passes issued accordingly.
- Involuntary Upgrade Incident
- At boarding Gate No. 28, ground attendant Clara Lai Han Chiu informed Vazquezes via computer message that they were upgraded to First Class due to overbooking of Business Class.
- Dr. Vazquez refused upgrade—preferred to travel with guests and conduct business; Ms. Chiu, under supervisor’s instruction, insisted refusal would bar them from boarding.
- After deliberation with companions, the Vazquezes relented and occupied First Class seats.
- Post‐Flight Correspondence and Suit
- On 2 October 1996, Vazquezes demanded ₱1 million indemnity for humiliation and written apologies.
- Cathay’s reply (14 October 1996) promised investigation; no substantive response by 8 November 1996.
- On 8 November 1996, the Vazquezes filed suit in RTC Makati for temperate (₱250,000 each), moral (₱500,000 each), exemplary (₱500,000 each), and attorney’s fees (₱250,000 each).
- Trial Court and Court of Appeals Decisions
- RTC (19 October 1998): found breach of contract in involuntary upgrade; awarded each spouse nominal ₱100,000; moral ₱2,000,000; exemplary ₱5,000,000; attorney’s fees ₱1,000,000.
- CA (24 July 2001): deleted exemplary damages; reduced moral to ₱250,000 each; nominal to ₱50,000 each; attorney’s fees ₱50,000 total; upheld breach by novation without consent.
Issues:
- Contractual Breach
- Whether involuntary upgrade from Business to First Class constituted breach of contract of carriage.
- Bad Faith or Fraud
- Whether the upgrade was tainted by fraud, deceit, or bad faith warranting moral or exemplary damages.
- Entitlement to Damages
- Whether respondents are entitled to moral, exemplary, or nominal damages, and attorney’s fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)