Case Digest (G.R. No. 104235) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Cesar & Suthira Zalamea and Liana Zalamea v. TransWorld Airlines, Inc., decided on November 18, 1993 under G.R. No. 104235, petitioners Cesar and Suthira Zalamea and their daughter Liana purchased three confirmed tickets from the Manila agent of respondent TransWorld Airlines for TWA Flight 007 from New York to Los Angeles on June 6, 1984. The parents’ tickets were acquired at a 75% discount, while the daughter’s ticket was full fare. After reconfirming their reservations on June 4, petitioners arrived at the airport on the morning of departure, checked in at 10:00 a.m., but were placed on a wait-list due to overbooking; Liana was No. 13 on the list, and her parents were No. 34 as a group of two. Only the first 22 wait-listed passengers boarded, including Cesar who held the full-fare ticket for his daughter, while Suthira and Liana were denied seats. Subsequent attempts to travel on the next TWA flight failed, compelling them to purchase two American Airlines tickets Case Digest (G.R. No. 104235) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners: Spouses Cesar and Suthira Zalamea, and their daughter Liana Zalamea.
- Respondent: TransWorld Airlines, Inc. (TWA), with appeal from Regional Trial Court (RTC) Makati, Branch 145, to the Court of Appeals (CA).
- Ticket Purchase and Confirmation
- On June 6, 1984, petitioners held confirmed seats on TWA Flight 007 from New York to Los Angeles—two at 75% discount (spouses) and one full fare (daughter).
- On June 4, 1984, petitioners received reconfirmation notices of their reservations.
- Check-in and Overbooking
- Petitioners checked in at 10:00 am for an 11:00 am flight, but seats were filled; they were placed on a 42-name wait-list:
- Liana Zalamea at No. 13.
- Spouses together at No. 34 (party of two).
- Only the first 22 on the list were boarded, including Cesar (holding Liana’s full-fare ticket); Suthira and Liana were bumped.
- Alternative Arrangements and Trial Court Proceedings
- Suthira and Liana purchased American Airlines tickets for US$918.00 to reach Los Angeles.
- Upon return to the Philippines, petitioners sued for breach of contract of carriage.
- RTC (Jan. 9, 1989) awarded:
- US$918.00 (American Airlines tickets).
- Full and discounted TWA ticket refunds (US$159.49; ₱8,934.50).
- ₱250,000 moral damages; ₱100,000 attorney’s fees; costs.
- Court of Appeals Decision
- CA (Oct. 25, 1991) recognized breach but held no bad faith or fraud, as U.S. Civil Aeronautics Board regulations permit overbooking.
- CA eliminated moral/exemplary damages; awarded:
- US$159.49 × 2 (refund of TWA tickets for Suthira and Cesar).
- ₱50,000 attorney’s fees; costs.
Issues:
- Whether TWA committed fraud or bad faith by overbooking and denying confirmed seats.
- Whether moral and exemplary damages are proper absent proof of bad faith.
- Whether petitioners are entitled to:
- Refund of Liana’s unused TWA ticket.
- Reimbursement for American Airlines tickets.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)