Case Digest (G.R. No. 186305) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In V-Gent, Inc. v. Morning Star Travel and Tours, Inc. (G.R. No. 186305, July 22, 2015), petitioner V-Gent, Inc. (V-Gent) is a corporate travel agency that, in June and September 1998, purchased twenty-six two-way Manila-Europe-Manila airline tickets from respondent Morning Star Travel and Tours, Inc. (Morning Star). On June 24 and September 28, 1998, V-Gent returned fifteen unused tickets valued at US$8,747.50, of which Morning Star refunded six tickets worth US$3,445.62 and refused to refund the remaining nine tickets despite repeated demands. On December 15, 2000, V-Gent filed a complaint for the unrefunded amount of US$5,301.88 plus attorney’s fees before Branch 2 of the Metropolitan Trial Court (MeTC) of Manila (Civil Case No. 169296-CV). Morning Star countered that (1) the “buy one, take one” promotion limited refunds to 50% of unused tickets; (2) V-Gent lacked personality to sue; and (3) the real parties-in-interest were the passengers whose names appeared on the tickets. Case Digest (G.R. No. 186305) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Ticket Purchase and Refund
- In June and September 1998, V-Gent, Inc. (V-Gent) purchased twenty-six two-way Manila–Europe–Manila plane tickets from Morning Star Travel and Tours, Inc. (Morning Star).
- V-Gent returned fifteen unused tickets (worth US$8,747.50) on June 24 and September 28, 1998; Morning Star refunded six tickets (US$3,445.62) but refused to refund the remaining nine (US$5,301.88) despite repeated demands.
- Trial Court Proceedings
- On December 15, 2000, V-Gent filed a money claim in the MeTC (Civil Case No. 169296-CV) for the unrefunded US$5,301.88 plus attorney’s fees; Morning Star countered that the tickets were sold under a “buy one, take one” promo and that only seven of fourteen unused tickets were refundable and questioned V-Gent’s standing.
- On January 27, 2006, the MeTC dismissed the complaint for lack of cause of action and held that V-Gent, as agent of the passengers, failed to prove its claim by a preponderance of evidence.
- Appeals and Court of Appeals Decision
- V-Gent appealed to the RTC (Civil Case No. 06-115050), which on September 25, 2006 reversed the MeTC, finding V-Gent had established its claim and ordering Morning Star to pay for the nine unrefunded tickets plus attorney’s fees.
- Morning Star appealed to the Court of Appeals (CA-G.R. SP No. 97032), which on November 11, 2008 granted the petition, dismissed V-Gent’s complaint for lack of standing, and denied reconsideration on February 5, 2009.
Issues:
- Standing of V-Gent as Real Party-in-Interest
- Whether the MeTC’s finding that V-Gent was the real party-in-interest became final and binding.
- Whether V-Gent, as agent of the ticket passengers, has legal standing to sue in its own name.
- Estoppel by Partial Refund
- Whether Morning Star’s partial refund estops it from contesting V-Gent’s standing to file suit.
- Whether acceptance of refund implies authority to litigate on behalf of the passengers.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)