G.R. No. 213418 - Ramos vs. China Southern Airlines Co., Ltd.

On 7 August 2003, petitioners purchased five roundtrip plane tickets from Active Travel Agency at the cost of US$985.00.
The issued itineraries indicated that petitioners were scheduled to depart Manila on 8 August 2003 at 0900H and return from Xiamen on 12 August 2003 at 1920H.

Petitioners successfully boarded the flight to Xiamen International Airport without incident.
No problems were encountered during the outbound leg of the journey.

For the return flight, despite prior confirmation by an agent from Active Travel, petitioners encountered difficulties.
After completing required procedures such as check-in, payment of terminal fees, and receiving baggage claim stubs, they were informed by the airline’s representative that they were "chance passengers."
Petitioners were presented with the option to board if they paid an additional fee of 500 Renminbi (RMB) per person.
Upon refusing to pay the extra amount, their baggage was offloaded and they were denied boarding as the flight departed without them.

Due to pre-existing business commitments in Manila, petitioners resorted to renting a car to reach Chuan Chio Station and subsequently boarded a train to Hong Kong.
In Hong Kong, they purchased new plane tickets from Philippine Airlines (PAL) and returned to Manila.
Upon arrival in Manila, petitioners sought redress from Active Travel by reporting the incident; the agency offered a refund for the ticket price, which petitioners declined.

Petitioners demanded a reimbursement of airfare and travel expenses totalling P87,375.00 from China Southern Airlines.
The airline, contending that petitioners were not confirmed passengers but merely chance passengers due to their failure to re-confirm their bookings 72 hours prior as indicated in the ticket, denied liability.
Consequently, petitioners filed an action for damages before the Regional Trial Court (RTC) of Manila (Civil Case No. 04-109574), seeking:

The RTC rendered a decision on 23 March 2009, awarding petitioners a total of P692,000.00, broken down as follows:

On appeal, the Court of Appeals (CA) affirmed the award of actual damages but deleted the moral and exemplary damages, reasoning that there was no evidence of bad faith or malice on the part of China Southern Airlines.
The CA subsequently modified its ruling via a Resolution dated 9 July 2014, ordering payment of interest on the awarded actual damages at 6% per annum from the finality of the CA’s decision.

Dissatisfied with the modifications, petitioners filed a Petition for Review on Certiorari before the Supreme Court.
Petitioners challenged the CA's deletion of moral and exemplary damages, its finding regarding the absence of bad faith in the bumping-off incident, and the starting point for the accrual of legal interest.

Whether the Court of Appeals erred in deleting the awards of moral and exemplary damages, given the established doctrine that bumped-off passengers are entitled to such damages.
Whether the CA committed an error by declaring that the bumping-off of petitioners was not attended by bad faith or malice, contrary to the findings of the lower court.
Whether the CA was incorrect in holding that legal interest should commence only from the finality of the decision rather than from the date of the extrajudicial demand (18 August 2003).