Case Digest (G.R. No. 130030) Core Legal Reasoning Model
Facts:
The case, Expertravel & Tours, Inc. vs. The Hon. Court of Appeals and Ricardo Lo, originates from a dispute over a contract for travel services. On October 7, 1987, Expertravel & Tours, Inc. (hereafter referred to as "Expertravel") issued four round-trip plane tickets to Ricardo Lo for travel to Hong Kong, along with hotel accommodations and transfers for a total amount of P39,677.20. Expertravel alleged that Lo failed to fulfill the payment obligation for these services and subsequently made several demands for payment that went unanswered.
In response, Expertravel filed a complaint in court seeking the recovery of the unpaid amount plus damages. Lo, however, contended that he had fully paid the outstanding charges. He provided evidence of payment through a Monte de Piedad Check No. 291559, dated October 6, 1987, for P42,175.20, which was remitted to Expertravel's then Chairperson, Ms. Ma. Rocio de Vega, who was authorized to handle client dealings. Ms.
Case Digest (G.R. No. 130030) Expanded Legal Reasoning Model
Facts:
- Transaction and Issuance of Tickets
- On October 7, 1987, Expertravel & Tours, Inc. (Expertravel), a domestic corporation engaged in the travel agency business, issued four round-trip plane tickets to respondent Ricardo Lo.
- The ticket package included hotel accommodations and transfers at a total cost of P39,677.20.
- Payment and Alleged Non-Payment
- Expertravel alleged that Lo failed to pay the amount due and proceeded with several demands for payment.
- In his defense, Lo maintained that his account with Expertravel had been fully settled.
- Remittance Process and Evidence of Payment
- The outstanding account was remitted by Lo through Expertravel’s then Chairperson, Ms. Ma. Rocio de Vega, who was authorized to transact on behalf of the company.
- The payment was evidenced by a Monte de Piedad Check No. 291559, dated October 6, 1987, for the amount of P42,175.20.
- In connection with this remittance, Ms. de Vega issued City Trust Check No. 417920 in favor of Expertravel for P50,000.00, with the notation “placement advance for Ricardo Lo, etc.”
- Expertravel acknowledged the receipt of the payment on October 10, 1987, as shown in its corresponding invoice.
- Judicial Proceedings and Decisions
- The Regional Trial Court (Branch 5) of Manila rendered judgment on November 7, 1994, dismissing the suit and ordering Expertravel to pay Lo moral damages of P30,000.00, attorney’s fees of P10,000.00, and costs, but withheld pronouncement on other damages due to insufficient evidence.
- The Court of Appeals subsequently affirmed in toto the trial court’s decision on March 20, 1997.
- Petitioned by Expertravel for review on certiorari, the case reached the Supreme Court.
- Contentions Raised in the Petition
- Petitioner Expertravel challenged the award of moral damages, citing, among others, the nature of the suit as clearly unfounded.
- The legal issues raised pertained to the propriety of awarding moral damages in cases of unfounded suits and for negligence or quasi-delict absent physical injury.
Issues:
- Can moral damages be recovered in a clearly unfounded suit?
- The petition questioned whether a suit that is otherwise unfounded could give rise to a valid claim for moral damages.
- Can moral damages be awarded for negligence or quasi-delict even when no physical injury has resulted?
- The petitioner inquired if the award of moral damages may extend to cases of negligence or quasi-delict where the injury is not of a physical nature.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)