G.R. No. 45186 - People vs. Bandian

Philippine Airlines, Inc. (PAL) is the petitioner, while the private respondents—Jaime M. Ramos, Nilda Ramos, Erlinda Ilano, Milagros Ilano, Daniel Ilano, and Felipa Javalera—are officers of the Negros Telephone Company.
The dispute arises from events on September 24, 1985, involving PAL Flight No. 264 from Naga City to Manila.

The private respondents purchased confirmed tickets in August 1985 for Flight No. 264 scheduled to depart at 4:25 p.m.
The tickets carried a specific condition clearly printed:

Passengers must check in at least one hour before the published departure time.
Failure to check in at least 30 minutes before departure would result in forfeiture of accommodation, with seats being allocated to waitlisted passengers.

The private respondents contended that they arrived at the check-in counter at least one hour before the scheduled departure.
It is alleged that no PAL personnel were present until 30 minutes before departure, causing undue delay.
Upon eventually being attended to, when the respondents presented their tickets, the check-in clerk annotated their tickets as “Late” (recorded at 4:02 p.m.), effectively canceling their seats and awarding them to chance or waitlisted passengers.
As a consequence, the respondents resorted to traveling by bus to Manila and claimed damages, including:

PAL maintained that the non-accommodation of the respondents was solely due to their late check-in and thus was in accordance with the contractual conditions printed on the tickets.
It was further alleged by PAL that the situation was compounded by the fact that the flight was fully booked—partly due to the Penafrancia Festival and the cancellation of other morning flights, which increased the number of waitlisted passengers.
PAL argued that even if found liable, any award should be limited by the provisions of CAB Economic Regulations No. 7 in conjunction with P.D. 589.

The Regional Trial Court of Imus, Cavite, Branch 21 rendered judgment against PAL, holding it liable for breach of contract of carriage, and ordered the payment of:

The Court of Appeals affirmed the trial court’s decision in toto on March 15, 1990.
PAL then elevated the case through a petition for review on certiorari, challenging both factual findings and the evidentiary basis of the damages awarded.

The tickets of the respondents clearly stated the check-in time condition.
Notations on the tickets made by the check-in clerk (indicative “Late” with the time of 4:02 p.m.) were central to the dispute.
The Passenger Manifest of Flight 264 confirmed the non-accommodation of not only the respondents but also other passengers (e.g., Go and Capati) due to late check-in.
A Daily Station Report from PAL detailed the deployment and functions of the personnel manning the check-in counter on September 24, 1985.

Edmundo Araquel, the check-in clerk, testified about the prompt annotation of the tickets and provided a timeline of events corroborated by the ticket markings and manifest entries.
Other witnesses, including passengers and personnel, testified on the assignment and activities at the check-in counter, reinforcing PAL’s account that personnel were present and performing their duties throughout the designated check-in period.

Whether the Court of Appeals validly promulgated its decision by adopting in toto the trial court’s findings based solely on the credibility of witnesses.
Whether the court properly considered the material admissions and documentary evidence (ticket conditions, annotations, passenger manifest, and daily station reports) that substantiate PAL’s defense.

Whether the appellate court erroneously awarded moral and temperate damages plus attorneys’ fees of P5,000.00 in contravention of the evidence on record and established jurisprudence.
Whether the damages awarded were excessive or inconsistent with the limitations imposed by the contractual conditions and relevant regulatory frameworks (e.g., CAB Economic Regulations No. 7 and P.D. 589).