Case Digest (G.R. No. 127473)
Facts:
In Philippine Airlines, Inc. v. Court of Appeals, private respondents Judy Amor, her infant son Gian Carlo Amor, her sister Jane Gamil, and minor Carlo Benitez (using Dra. Emily Chua’s ticket) purchased confirmed seats on Flight PR 178 bound for Manila on May 8, 1988, at Pal’s Legaspi branch. They arrived at Legaspi Airport at 6:20 a.m. for a 7:10 a.m. departure. At check-in, clerk Lloyd Fojas marked their tickets “late check-in 7:05” and refused boarding. Petitioner accommodated non-revenue and “go-show” passengers despite overbooking. Respondents sought alternative connections—PR 278 was canceled, and PR 180 only took confirmed passengers—resulting in respondents taking a night bus. They filed a complaint for breach of contract of carriage with the Regional Trial Court (RTC) Branch 53, Sorsogon, claiming reimbursement of tickets, actual, moral, and exemplary damages, and attorney’s fees. The RTC ruled for respondents and awarded ticket refunds, P100,000 as actual damages, P250Case Digest (G.R. No. 127473)
Facts:
- Purchase and Purpose
- Judy Amor purchased three confirmed tickets for Flight PR 178 on May 8, 1988 (herself, infant Gian Carlo Amor, sister Jane Gamil) from PAL’s Legaspi City office.
- She intended to transfer a fourth ticket (for Dra. Emily Chua) to nephew Carlo Benitez.
- The purpose was to attend the Philippine Dental Association National Convention in Manila (May 8–14, 1988).
- Check-in Attempt for PR 178
- Judy, Gian Carlo, Jane Gamil and Carlo Benitez arrived at Legaspi Airport at 6:20 a.m. for the 7:10 a.m. flight.
- Judy requested permission to transfer Chua’s ticket to Carlo; Atty. Owen Amor assisted.
- Lloyd Fojas, the check-in clerk, marked the tickets “late check-in 7:05” when Gonzales tendered them at 7:05 a.m.
- Respondents were refused boarding; PR 178 departed at 7:30 a.m.
- Subsequent Flight Attempts
- Respondents sought bus transport to Manila; found none and returned to the airport.
- PR 278 (2:30 p.m.) was canceled due to “aircraft situation.”
- On PR 180 (5:30 p.m.) they checked in but were denied boarding as chance/waitlisted passengers; boarding passes and baggage tags were removed.
- Evidence on Overbooking and Bumping
- Manuel Baltazar (former Acting Manager) testified confirmed passengers were bumped for non-revenue and waitlisted passengers; manifest showed overbooking beyond 10 %.
- PAL’s witness Fojas claimed respondents were late and that all confirmed passengers had checked in on PR 180.
- Lower Court Proceedings and Awards
- RTC (Branch 53, Sorsogon) found respondents checked in on time, overbooking occurred, and PAL acted in bad faith.
- Judgment ordered reimbursement of ticket fares, P250,000 moral damages each for Judy and Jane, P200,000 exemplary damages, P100,000 actual damages, attorney’s fees and costs.
- CA affirmed in toto; PAL filed petition under Rule 45.
Issues:
- Whether respondents were late check-in passengers and if PAL’s failure to accommodate is actionable.
- Whether the amounts of actual, moral, and exemplary damages awarded are excessive, unconscionable, or unreasonable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)