Case Summary (G.R. No. L-21438)
Petitioner and Respondent
– Petitioner challenged the Court of Appeals’ findings and awards against it for breach of contract, moral and exemplary damages, refund of fare difference, attorneys’ fees, interest, and costs.
– Respondent prosecuted an action for breach of contract of air carriage and quasi-delict arising from wrongful expulsion from his first-class seat at Bangkok.
Key Dates
– Ticket Issued: March 28, 1958
– Travel Date: March 30–31, 1958
– Trial Court Decision: Civil Case No. 38810, date not specified in record excerpt
– Court of Appeals Decision: C.A.-G.R. No. 26522-R, date not specified in excerpt
– Supreme Court Decision: September 28, 1966
Applicable Law
Constitution (1935 Constitution, Article VIII, Section 12 – decisions must state facts and law clearly)
Rules of Court: Rule 36, Section 1; Rule 51, Section 4; Judiciary Act of 1948, Section 33(2); Rule 45 (certiorari appeals limited to questions of law); Rules on Findings of Fact and Evidentiary Standards (best evidence rule; res gestae exception)
Civil Code: Article 21 (moral damages for willful injury contrary to morals, good customs or public policy); Article 2180 (employer liability for employees’ torts); Article 2220 (moral damages in contracts with fraud or bad faith); Article 2229 (quasi-delict/employer liability); Article 2232 (exemplary damages where defendant acts wantonly, fraudulently, recklessly, oppressively or malevolently); Article 2208 (attorneys’ fees)
Procedural History
- Trial Court (Court of First Instance of Manila) found for Carrascoso: awarded P25,000 moral damages, P10,000 exemplary damages, refund of P393.20 (first-class fare difference), interest, P3,000 attorneys’ fees and costs.
- Court of Appeals affirmed all awards except reduced fare refund to P383.10.
- Air France sought certiorari before the Supreme Court, challenging findings of fact, entitlement to seat, and damages awards.
Facts
Respondent joined a group of pilgrims on a first-class round-trip ticket from Manila to Rome with Hong Kong, Saigon, Bangkok, and Beirut as intermediate points. He occupied a first-class seat from Manila to Bangkok. At Bangkok, the airline’s Manager ordered him to surrender his seat—on the ground that a “white man” had a better right—forcing him into tourist class despite his protestations. The purser recorded in his notebook that “First-class passenger was forced to go to the tourist class against his will, and that the captain refused to intervene.”
Issue
Whether the Court of Appeals’ findings and conclusions regarding (a) entitlement to first-class accommodation, (b) breach of contract in bad faith, (c) liability for moral and exemplary damages and attorneys’ fees, and (d) admissibility of evidence, are supported by law and essential ultimate facts.
Standard of Review
Under certiorari appeal, only questions of law are entertained. Findings of fact by the Court of Appeals are binding unless the decision is utterly unsupported or violates the constitutional and statutory requirement to state essential ultimate facts.
Findings: Compliance with Constitutional and Statutory Mandates
The Supreme Court held that the Court of Appeals complied with Article VIII, Section 12 of the 1935 Constitution and Rule 51, Section 4 of the Rules of Court by stating the essential ultimate facts underlying its decision. A concise statement of determinative facts suffices; courts need not recite every evidentiary detail.
Findings: Contractual Obligation and Seat Entitlement
Both lower courts credited written tickets marked “O.K.” for first-class confirmation and witness testimony over petitioner’s oral evidence. The issuance of a first-class ticket, supported by documentary proof and admission of the company’s own witness, created an enforceable right to first-class accommodation.
Findings: Breach of Contract and Bad Faith
The forcible ejection of Carrascoso from his confirmed first-class seat in order to accommodate another passenger constituted a breach of the carriage contract in bad faith. Bad faith was inferred from the arbitrary act of the Manager, the absence of any justification or prior reservation for the other passenger, and petitioner’s failure to present the Manager’s testimony.
Findings: Employer Liability
Under Civil Code Article 2180 and related precedents, petitioner is vicariously liable for the tortious and bad-faith acts of its Manager. The willful act of wrongful ejection violated public policy and gave rise to moral damages.
Findings: Natu
Case Syllabus (G.R. No. L-21438)
Facts of the Case
- Rafael Carrascoso, a Filipino civil engineer, joined 48 pilgrims departing Manila on March 30, 1958, bound for Lourdes and Europe.
- On March 28, 1958, Air France, through Philippine Air Lines, issued Carrascoso a “first class” round-trip ticket from Manila to Rome.
- Carrascoso traveled first class from Manila to Bangkok. At Bangkok, the airline’s manager forcibly removed him from his first-class seat to accommodate a white passenger, despite Carrascoso’s refusal and protest.
- A commotion ensued; fellow Filipino passengers intervened, and Carrascoso reluctantly vacated his seat. He thereafter used Pan American World Airways for part of his return trip to avoid further humiliation.
Procedural History
- Court of First Instance of Manila: Ordered Air France to pay P25,000 moral damages, P10,000 exemplary damages, P393.20 fare difference, interest, P3,000 attorneys’ fees, and costs.
- Court of Appeals: Affirmed the decision except reduced the fare difference award to P383.10; imposed costs against Air France.
- Supreme Court: Review on certiorari limited to questions of law; factual findings of appellate court deemed conclusive in absence of prejudicial error.
Issue on Findings of Fact
- Air France contended the Court of Appeals failed to make complete findings on all issues, breaching constitutional and statutory mandates for clear and distinct facts.
- Supreme Court clarified that only “essential ultimate facts” are required; courts need not recite every piece of evidence or detail every defense contention.
- Presumption of regular judicial performance applies; absence of detailed findings on defense evidence does not invalidate the decision.
Right to First-Class Seat and Ticket Confirmation
- Undisputed that Carrascoso paid for and received a confirmed