Title
V-Gent, Inc. vs. Morning Star Travel and Tours, Inc.
Case
G.R. No. 186305
Decision Date
Jul 22, 2015
V-Gent, acting as an agent for passengers, sued Morning Star for unrefunded plane tickets. Courts ruled V-Gent lacked legal standing, as passengers were the real parties-in-interest. Petition denied.

Case Digest (G.R. No. 186305)
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)

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