Title
Morris vs. Court of Appeals
Case
G.R. No. 127957
Decision Date
Feb 21, 2001
American executives with confirmed first-class bookings denied boarding on SAS flight due to late check-in; Supreme Court ruled no damages as no bad faith or fraud proven.

Case Digest (G.R. No. 154953)

Facts:

  • Background of the Case
    • On February 14, 1978, petitioners Collin A. Morris and Thomas P. Whittier, both American citizens and officers of Sterling Asia, filed an action for damages for breach of contract of air carriage against Scandinavian Airlines System (SAS).
    • The dispute arose when the petitioners, having a confirmed first-class booking on SAS Flight SK 893 (Manila–Tokyo), were bumped off the flight.
    • The petitioners had business engagements in Japan from February 14 to 22, 1978 and arranged travel through Staats Travel Service, Inc. which secured their confirmed booking.
  • Chronology of Events on February 14, 1978
    • Travel Arrangements and Departures
      • A limousine service from the travel agency fetched petitioner Morris from his residence in Urdaneta Village, Makati City at 1:30 p.m.
      • The petitioners proceeded to pick up petitioner Whittier at Merville Park, Parañaque and then headed to Manila International Airport, arriving at approximately 2:35 p.m.
    • Check-in Process
      • Upon arrival at the airport, the petitioners met representatives of their travel agency and then approached the SAS check-in counter.
      • They presented all their travel documents – tickets, passports, and immigration cards – to Ms. Erlinda Ponce, the SAS employee on duty.
      • After a waiting period of approximately 15 minutes, they noted that their travel documents were not being processed, and were informed that no seats remained on the flight.
    • Communication and Confirmations
      • Petitioners contacted Staats Travel Service, which allegedly reconfirmed their booking after a delay of about ten minutes.
      • The petitioners then returned to the SAS counter expecting to be accommodated; however, the counter had closed and staff, including Ms. Ponce and supervisor Raul Basa, refused further assistance.
    • Manifest Discrepancy
      • Petitioners observed that their names, initially listed in the first-class section, had been crossed out and marked with “NOSH” (interpreted as NO SHOW).
      • According to Ms. Ponce and later corroborated by supervisor Basa, the closure of the flight manifest occurred 40 minutes before the scheduled departure at 3:50 p.m.
      • It was explained that, due to overbooking in economy class, waitlisted economy passengers had been upgraded to first class when petitioners checked in later than the required cutoff time.
    • Trial Court and Subsequent Developments
      • On August 24, 1988, the trial court ruled in favor of the petitioners and ordered SAS to pay moral damages, exemplary damages, and attorney’s fees.
      • A notice of appeal was subsequently filed by the respondent on October 5, 1988, and the petitioners moved for reconsideration regarding the damage award on October 6, 1988.
      • On February 26, 1992, the trial court modified the award by increasing the amount of moral damages.
    • Court of Appeals Decision
      • On January 21, 1997, the Court of Appeals reversed the trial court’s decision, dismissing the petitioners’ complaint for damages.
      • The appellate court found the petitioners’ testimonies self-serving and insisted that the evidence confirmed that they checked in late—after the manifest was closed.
    • Arguments Presented on Certiorari
      • Petitioners argued that they arrived in time given their confirmed bookings and prior travel practices that required early airport arrival.
      • Respondent contended that the petitioners’ failure to adhere to the check-in deadlines led to their being bumped off, thereby negating any claim for damages under the breach of the contract of air carriage.
  • Evidentiary Testimonies and Supporting Facts
    • Testimony of Ms. Erlinda Ponce
      • Confirmed that the economy class was overbooked, whereas the first class section was open at first.
      • Asserted that the petitioners checked in after the flight manifest was closed, and that their first class seats were subsequently allocated to upgraded economy class passengers.
    • Testimony of Supervisor Raul Cruz Basa
      • Corroborated that petitioners’ names were crossed out on the manifest and that the “NO SHOW” notation indicated their late arrival.
      • Claimed he encountered the petitioners around 3:20 p.m. and explained that proper check-in had already concluded.
    • Testimony of Alice Magtulac
      • Confirmed the petitioners’ initially secured reservations for first class.
      • Noted that it was against SAS policy to upgrade economy passengers to first class due to no-shows in the first class section.
    • The Entire Chain of Events
      • Establishes that the entire issue stemmed from the petitioners arriving (or being processed) after the designated check-in period had closed.
      • Demonstrates procedural adherence by SAS, despite the petitioners’ assertions of timely arrival based on prior travel experiences.

Issues:

  • Whether the petitioners’ complaint for damages for breach of contract of air carriage is valid despite their alleged late check-in.
    • Determination of whether the petitioners arrived at the airport in sufficient time to be accommodated as first class passengers.
    • The extent to which the timing of check-in affected the airline’s duty to honor the confirmed booking.
  • Whether the actions of SAS constituted bad faith, fraud, or malice sufficient to warrant an award of moral and exemplary damages.
    • Analysis of the airline’s policies on check-in times and manifest closure.
    • Assessment of the evidentiary basis of the petitioners’ claim that they were “wrongfully bumped off” despite their confirmed reservation.
  • Whether the award of moral damages and exemplary damages should stand in cases where no fraudulent or bad faith conduct is proven in breaches of contract of carriage.
    • The legal threshold for recovering moral damages in contractual relations involving air carriage.
    • The implications of late check-in on compensability for non-material damages.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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