Facts:

The case involves Philippine Airlines, Inc. (PAL) as the petitioner and Jaime M. Ramos, Nilda Ramos, Erlinda Ilano, Milagros Ilano, Daniel Ilano, and Felipa Javalera as the respondents. The events leading to the case occurred on September 24, 1985, when the respondents, who were officers of the Negros Telephone Company, held confirmed tickets for PAL Flight No. 264 from Naga City to Manila, scheduled to depart at 4:25 p.m. The tickets were purchased in August 1985, and the conditions of the tickets specified that passengers must check in at least one hour before the published departure time, with a strict policy that accommodations would be forfeited if check-in was not completed at least 30 minutes prior to departure.

On the day of the flight, the respondents arrived at the check-in counter at least one hour before the scheduled departure time, but they claimed that no PAL personnel were present until 30 minutes before the flight. When they were finally attended to, their...

Facts:

1. Parties Involved:

• Petitioner: Philippine Airlines, Inc. (PAL)
• Respondents: Jaime M. Ramos, Nilda Ramos, Erlinda Ilano, Milagros Ilano, Daniel Ilano, and Felipa Javalera

2. Background:

• The respondents were officers of the Negros Telephone Company who held confirmed tickets for PAL Flight No. 264 from Naga City to Manila on September 24, 1985, scheduled to depart at 4:25 p.m.
• The tickets were purchased in August 1985 and included a condition requiring passengers to 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 the seat in favor of waitlisted passengers.

3. Incident:

• The respondents claimed they arrived at the check-in counter at least one hour before departure but found no PAL personnel present until 30 minutes before departure. When they finally checked in, their tickets were canceled, and their seats were given to chance passengers.
• As a result, the respondents had to travel to Manila by bus and subsequently filed a complaint for breach of contract of carriage, seeking actual, moral, and exemplary damages, as well as attorney's fees.

4. PAL's Defense:

• PAL argued that the respondents checked in late and were therefore not accommodated on the flight. PAL also contended that its liability, if any, was limited by the Civil Aeronautics Board (CAB) Economic Regulations No. 7 and Presidential Decree No. 589.

5. Trial Court Decision:

• The Regional Trial Court (RTC) ruled in favor of the respondents, finding PAL guilty of breach of contract of carriage. The court awarded:
  • P1,250.20 for the total value of the tickets.
  • P22.50 for airport security and terminal fees.
  • P20,000.00 to each respondent for moral and temperate damages.
  • P5,000.00 for attorney's fees and litigation expenses.

6. Court of Appeals Decision:

• The Court of Appeals affirmed the RTC's decision in toto.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Preponderance of Evidence:

   • In civil cases, the party with the more credible and conclusive evidence prevails. PAL's documentary evidence, including the tickets and passenger manifest, was more reliable than the respondents' testimonies.

2. Contractual Obligations:

   • The respondents were bound by the terms of the contract of carriage, which included the check-in time requirement. Their failure to comply with this condition absolved PAL of liability.

3. Damages:

   • Moral and temperate damages are not recoverable when the plaintiff's own actions or inactions caused the alleged harm. Since the respondents failed to check in on time, they were not entitled to damages.

4. Attorney's Fees:

   • Attorney's fees are only awarded when a party's act or omission has compelled the other party to incur expenses to protect their interest. Since PAL was not at fault, the award of attorney's fees was improper.

ACCORDINGLY, the petition is GRANTED. The questioned decision of the Court of Appeals dated March 15, 1990 is hereby ANNULLED and SET ASIDE. No costs. SO ORDERED.