Case Digest (G.R. No. 185891) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Cathay Pacific Airways v. Reyes, decided on June 26, 2013 under the 1987 Constitution, petitioners Cathay Pacific Airways and Sampaguita Travel Corp. were sued by respondents Wilfredo Reyes, his wife Juanita, their son Michael Roy, and Juanita’s mother Sixta Lapuz for alleged breach of contract of carriage and negligent booking arrangements. In March 1997, Wilfredo booked round-trip tickets Manila–Hong Kong–Adelaide–Hong Kong–Manila for his family through Sampaguita Travel. Four confirmed outbound seats were secured, but the return segments were mishandled: only Sixta’s booking remained confirmed, while the others were either canceled or never validly ticketed due to confusing Passenger Name Records (PNRs). On April 4, 1997, respondents arrived in Adelaide, reconfirmed their return, and flew to Hong Kong, where Wilfredo was again told his family lacked confirmed seats. Sixta alone flew to Manila; the rest waited overnight and flew home the next day. The Reyeses then demanded Case Digest (G.R. No. 185891) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Booking and issuance of tickets
- In March 1997, Wilfredo Reyes booked, through Sampaguita Travel Corp., round-trip Manila–Hong Kong–Adelaide tickets for himself, his wife Juanita, son Michael Roy, and mother-in-law Sixta Lapuz. Four PNRs/record locators were issued (J76TH, HDWC3, H9VZF, HTFMG) upon full payment.
- The party departed Manila on 12 April 1997 and flew to Adelaide without incident.
- Return flight reconfirmation and denied boarding
- One week before return, Wilfredo reconfirmed the family’s return reservations in Adelaide; staff assured him the bookings were “still okay as scheduled.”
- On 4 May 1997 at Adelaide, only Sixta’s booking remained confirmed; the other three passengers were told their reservations had been cancelled but were permitted to board to Hong Kong after Wilfredo’s pleas.
- In Hong Kong, only Sixta could board to Manila; the others were denied boarding on the fully booked flight and had to wait overnight for the next day’s service.
- Demand for damages and filing of complaint
- Upon return to Manila, Wilfredo reported to Sampaguita Travel, which blamed Cathay Pacific for cancelling the bookings.
- On 16 June 1997, respondents sent a demand letter to Cathay Pacific for P1,000,000 moral damages, P300,000 actual damages, P100,000 exemplary damages, and P100,000 attorney’s fees.
- Failing resolution, respondents filed a Complaint for damages against Cathay Pacific and Sampaguita Travel.
- Defendants’ answers and cross-claims
- Cathay Pacific alleged multiple conflicting PNRs from Sampaguita Travel and another agency, showing no valid ticketing for three passengers, and filed a cross-claim against Sampaguita Travel.
- Sampaguita Travel denied liability, asserted it properly secured confirmed bookings and issued tickets, and counter-claimed against Cathay Pacific.
- Trial court proceedings and decision
- Parties stipulated that respondents dealt only with the travel agent, held valid tickets for outbound flights, and that flight cancellation was within airline control.
- The RTC found no breach by either defendant, noted booking confusion from multiple PNRs, and dismissed the complaint and all counter-/cross-claims for lack of merit.
Issues:
- Whether Cathay Pacific is liable for nominal damages for an alleged initial breach of contract of carriage despite proving no fault.
- Whether the Court of Appeals relied on matters not proved at trial in awarding nominal damages.
- Whether Cathay Pacific erred in holding it liable for nominal damages to Sixta Lapuz.
- Whether Sampaguita Travel should have been held liable to Cathay Pacific for any damages.
- Whether the appellate court should have applied stare decisis in fixing the amount of nominal damages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)