Title
Philippine Airlines, Inc. vs. Ramos
Case
G.R. No. 92740
Decision Date
Mar 23, 1992
The Supreme Court rules in favor of Philippine Airlines, Inc. (PAL) in a breach of contract case, finding that the passengers' late check-in justified the cancellation of their tickets and absolving PAL of liability for damages.
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Case Digest (G.R. No. 92740)

Facts:

  • Philippine Airlines, Inc. (PAL) is the petitioner.
  • Respondents: Jaime J. Ramos, Hilda Ramos, Erlinda Ilano, Milagros Ilano, Daniel Ilano, and Felipa Javalera.
  • Date: September 24, 1985.
  • Location: Naga City Airport.
  • Respondents were officers of the Negros Telephone Company.
  • They held confirmed tickets for PAL Flight No. 264 from Naga City to Manila, scheduled to depart at 4:25 p.m.
  • Respondents claimed to have arrived at the check-in counter at least one hour before departure.
  • No PAL personnel were present until 30 minutes before departure.
  • Their tickets were canceled, and seats were given to waitlisted passengers.
  • Respondents traveled to Manila by bus.
  • They sought actual, moral, and exemplary damages, plus attorney's fees, for breach of contract of carriage.
  • The Regional Trial Court of Imus, Cavite, Branch 21, found PAL guilty of breach of contract and awarded damages and fees.
  • PAL appealed to the Court of Appeals, which affirmed the trial court's decision.
  • PAL filed a petition for review on certiorari with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court granted the petition.
  • The decision of the Court of Appeals dated March 15, 1990, was annulled a...(Unlock)

Ratio:

  • In civil cases, the burden of proof lies with the party asserting the affirmative allegations.
  • The required degree of evidence is preponderance of evidence.
  • The main factual issue was whether the respondents were late in checking in for their flight.
  • PAL's documentary evidence, including plane tickets with the "late" notation and the passenger manifest, was given more weight than the respondents' oral testimonies.
  • Respondents failed to provide substantial and convincing evidence to count...continue reading

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