G.R. No. 166547 - Tomawis vs. Tabao-Caudang

Petitioner Victorino Savellano was a former mayor of Cabugao, Ilocos Sur, a former Chairman of the Commission on Elections, and a Regional Trial Court judge.
Petitioner Virginia B. Savellano is a businesswoman who operates several rural banks in Ilocos Sur.
Petitioner Deogracias B. Savellano, their son, was the incumbent Vice-Governor of Ilocos Sur at the time of the incident.

The petitioners purchased NW round-trip tickets at Northwest Airlines’ Manila ticketing office for a scheduled itinerary: San Francisco – Tokyo (Narita) – Manila, set for October 27, 1991, with an expected arrival in Manila on October 29, 1991 (after approximately 12 hours of travel).
The airline ticket carried specific conditions, including Condition 9 which allowed substitution of alternate carriers or aircraft and alteration or omission of stopping places only “in case of necessity.”

Approximately two and a half hours into the flight on October 27, 1991, an engine malfunction (fire incident) forced an emergency landing in Seattle.
Upon landing at Seattle Airport, the passengers were instructed to wait and then repatriated the next day using the same boarding passes and seating arrangements.
The petitioners and other passengers were transported by a shuttle bus to the Seattle Red Lion Hotel, where they were billeted at the expense of the airline.

The petitioners were awakened at midnight by a call from airline personnel instructing them to be at Seattle Airport early in the morning to catch a flight departing on October 28, 1991 instead of the originally scheduled connecting flight.
Prior to departure, they were informed by a co-passenger, Col. Roberto Delfin, that other passengers were scheduled to travel on October 29, 1991, highlighting a discrepancy in treatment.
At Seattle Airport, a NW ground stewardess communicated that instead of flying directly to Manila, the petitioners would have to board Flight 94 bound for Los Angeles, from which they would connect via Seoul and ultimately reach Manila—a departure from the original itinerary.

The petitioners’ three small handcarried items, which were not padlocked but simply closed by zippers, were not allowed to be placed in the passengers’ baggage compartment by a NW ground stewardess.
Upon arriving at Ninoy Aquino International Airport (NAIA), petitioners discovered that the contents of the handcarried items had been ransacked.
The alleged losses included valuable items such as diamond earrings, luxury shoes, watches, and perfumes claimed by Virginia, and personal items including shoes, clothes, a camera, a personal computer, and jeans claimed by Deogracias.

On November 22, 1991, the petitioners, through counsel, demanded ₱3,000,000.00 as damages for the humiliation and inconvenience suffered, a demand which was not acceded to by the respondent.
The petitioners filed a case for damages at the Regional Trial Court (RTC) of Cabugao, Ilocos Sur, where the RTC rendered judgment in their favor, awarding actual, moral, exemplary damages, and attorney’s fees.
The Court of Appeals (CA) reversed the RTC decision on several points, particularly with regard to the award of moral and exemplary damages, as well as actual damages, based on the argument that there was no evidence of bad faith, negligence, or malice, and that the petitioners’ claims were not supported by convincing evidence.

Whether petitioners’ exclusion from NW Flight No. 0027 on October 28, 1991, due to the unilateral change of the flight’s stopping places, constitutes a breach of the air-carriage contract.
Whether the unilateral decision to reroute the petitioners without their consent to Los Angeles and Seoul violates the specific provisions stipulated in the ticket conditions.

Whether the petitioners are entitled to recover actual, moral, and exemplary damages as a consequence of the altered flight itinerary.
Whether the specific circumstances, including the alleged inconvenience, embarrassment, and loss of valuables, justify damages beyond nominal consideration, taking into account the absence or presence of bad faith, negligence, or malice on the part of the respondent.