Case Digest (G.R. No. 249410)
Facts:
This case involves Philippine Airlines, Inc. (PAL) as petitioner, against respondents Francisco Lao Lim, the heirs of Henry Go, Manuel Limtong, and Rainbow Tours and Travel, Inc. The respondents, all Cebu-based businessmen engaged in different ventures, planned a business trip to Hongkong involving purchase negotiations for weighing scales and printing press equipment. On February 22, 1991, Francisco Lao Lim purchased three confirmed roundtrip PAL tickets through Rainbow Tours for flights from Cebu to Hongkong scheduled for February 25-26, 1991, with return on March 1, 1991. On February 23, 1991, Lim inquired about booking seats for a later flight at 5:00 p.m. on February 26 due to rescheduling needs but did not cancel the original confirmed tickets. On the day of the flight, February 26, 1991, PAL's check-in personnel at Ninoy Aquino International Airport informed Francisco Lao Lim and Henry Go that their confirmed bookings for the 8:00 a.m. Manila-Hongkong flight had been
Case Digest (G.R. No. 249410)
Facts:
- Parties and Background
- Plaintiffs: Francisco Lao Lim (real estate and trading), Henry Go (export and distribution of weighing scales), and Manuel Limtong (printing press business), Cebu-based businessmen.
- Respondents/Defendants: Philippine Airlines, Inc. (PAL) as petitioner; Rainbow Tours and Travel, Inc. as third-party defendant.
- Business Trip to Hongkong
- Plaintiffs planned business transactions involving purchase of weighing scales from Mrs. Ng Yuen Ming of Hongkong and printing press equipment from Mrs. Myrna Irsch of Germany.
- Important appointments scheduled for February 26, 1991, for concluding agreements and signing contracts.
- Flight Bookings and Changes
- On February 22, 1991, Francisco Lao Lim purchased three (3) confirmed PAL roundtrip tickets via Rainbow Tours:
- PR842 Cebu-Manila, Feb 25, 1991, 12:05 P.M.
- PR300 Manila-Hongkong, Feb 26, 1991, 8:00 A.M.
- Return trip - PR301 Hongkong-Manila and PR512 Manila-Cebu on March 1, 1991.
- On February 23, 1991, Lao Lim inquired at Rainbow Tours regarding availability of seats for PR310 Manila-Hongkong, Feb 26, 1991 at 5:00 P.M. to reschedule appointments.
- Agent Gemma Dingal called PAL; no seats available for 5:00 P.M. flight. No cancellation was made by plaintiffs to their confirmed bookings.
- Denial of Boarding and Resulting Delay
- On February 25, 1991, plaintiffs took PR842 Cebu-Manila flight.
- On February 26, 1991, at NAIA check-in, Lao Lim and Henry Go were informed their PR300 Manila-Hongkong bookings were cancelled; their names were not in passenger list.
- Manuel Limtong was able to board PR300 flight.
- Lao Lim and Go pleaded to board but were refused. They took PR301 at 5:00 P.M. same day (late flight).
- Claims for Damages
- Plaintiffs sued PAL for breach of contract of carriage and damages, alleging:
- Humiliation and rude treatment by PAL’s check-in clerks ("cheap tickets" remark).
- Lost business opportunities valued at P3,567,000.00 due to missing appointments.
- Moral damages of P350,000.00 each for humiliation and injury.
- Exemplary damages and attorney’s fees.
- PAL’s Defense and Third-Party Impleader
- PAL claimed:
- Plaintiffs were revenue passengers with travel arranged through Rainbow Tours.
- Bookings for Lao Lim and Go on PR300 were cancelled upon instruction of Gemma Dingal of Rainbow Tours.
- Cancellation was due to overbooking and full capacity of PR310 5:00 P.M. flight.
- Erroneous reinstatement requests and unresolved status prevented restoration of original bookings.
- PAL impleaded Rainbow Tours for indemnity/contribution as third-party defendant.
- PAL employees testified on cancellation process and on courteous treatment policies.
- Rainbow Tours witnesses attributed erroneous cancellation to PAL’s employee Racil Corcuera, denying instructions to cancel.
- Trial Court and CA Decisions
- RTC (June 18, 1996) found PAL and Rainbow Tours jointly liable:
- P75,000.00 temperate damages to Lao Lim and heirs of Henry Go each.
- P25,000 attorney’s fees.
- Both parties appealed.
- CA (March 22, 2005) modified RTC decision:
- Ordered joint and several liability of PAL and Rainbow Tours to pay:
- P50,000 moral damages + P50,000 exemplary damages to Lao Lim and heirs of Henry Go each.
- P100,000 temperate damages each to plaintiffs (Lao Lim, Go, Limtong).
- P60,000 attorney’s fees aggregate.
- Denied PAL’s claims for contribution/indemnity from Rainbow Tours.
- Costs against PAL and Rainbow Tours.
- PAL’s motion for reconsideration denied (July 15, 2005).
- Present Petition by PAL before the Supreme Court
- The December 22 CA decision did not address petitioner’s rehabilitation receivership motion.
- Lao Lim and Henry Go did not hold confirmed bookings for PR300 on Feb 26, 1991 as they were cancelled per Gemma Dingal’s instructions.
- Henry Go/heirs did not testify; thus, no basis for moral and exemplary damages.
- Manuel Limtong not entitled to damages because he boarded the flight without issues.
- Temperate damage awards lack factual and legal basis.
- Only Rainbow Tours should be liable; PAL should be absolved.
Issues:
- Whether the petitioner's motion to suspend proceedings based on rehabilitation receivership was properly resolved.
- Whether respondents Francisco Lao Lim and Henry Go held confirmed bookings on PAL flight PR300 scheduled February 26, 1991.
- Whether the evidence supports the awards of moral, exemplary, temperate or moderate damages and attorney’s fees to the respondents.
- Whether respondent Manuel Limtong is entitled to damages despite boarding the scheduled flight without incident.
- Whether Rainbow Tours and Travel, Inc. alone should be held liable for damages or whether PAL shares liability.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)