Case Summary (G.R. No. 221370)
Factual Background
In October 1977, Narciso Morales purchased an airline ticket through Aspac Management Corporation, Air France's General Sales Agent located in Makati. The total cost of the ticket was P9,426.00, excluding an additional travel tax. The itinerary consisted of multiple legs with certain restrictions specifically stating “non-endorsable” and “valid on Air France only.” On November 3, 1977, while in New York, Morales experienced an ear infection that required medical attention, prompting him to seek a rerouting of his ticketed journey.
Communications and Airline Response
Despite Morales's medical condition, Air France representatives initially refused to validate Morales's request for a rerouting of his ticket to a shorter route. After an unsuccessful attempt for a reroute from Copenhagen, Morales eventually purchased new tickets for his return journey, incurring additional significant expenses.
Trial Court’s Decision
The complaint was filed against Air France for breach of contract and for damages. The trial court, presided over by Judge Marcelino Sayo, found in favor of Morales, awarding him actual, moral, and exemplary damages after determining that Air France acted in evident bad faith by failing to accommodate Morales’s request and exhibiting a threatening demeanor through its employees.
Court of Appeals Ruling
Air France appealed the trial court's decision to the Court of Appeals. The appellate court modified the damage award but upheld the trial court's finding of breach of contract. The adjusted award included specific amounts for actual damages, reduced moral damages, and a provision for attorney's fees.
Grounds for Supreme Court Review
Air France subsequently sought a review by the Supreme Court, arguing that the appellate court's conclusion of breach of contract rested on a misapprehension of the facts, failed to consider the doctrine of avoidable consequences, and resulted in an award of damages deemed exorbitant.
Supreme Court's Analysis
In its review, the Supreme Court emphasized that it is not a trier of facts but can reconsider cases where the lower court’s findings lack specific supporting evidence. The Court assessed the basis of the appellate court's determination that a breach of contract occurred and noted the stipulated restrictions on Morales's original ticket. The Court referenced the International Air Transport Association (IATA) regulations that govern ticket fare restrictions, affirming that Air France's refusal to allow rerouting was not unreasonable, especially given the evidence of ticket restr
...continue readingCase Syllabus (G.R. No. 221370)
Case Background
- The case involves a petition for review on certiorari filed by Air France against the decision of the Court of Appeals dated April 4, 1986, which dismissed Air France's appeal from an adverse ruling by the trial court in Rizal, Kalookan City.
- The trial court's decision, presided over by Judge Marcelino Sayo, found Air France liable for breach of contract of carriage and awarded damages to private respondent Narciso O. Morales.
Factual Context
- In October 1977, Narciso Morales, through his representative, purchased an airline ticket from Aspac Management Corporation, the General Sales Agent for Air France, for a total of P10,839.90, which included a travel tax.
- The ticket had specific restrictions noted as "non-endorsable" and "valid on AF only" for certain segments of the journey, which spanned multiple international cities.
Medical Condition and Request for Rerouting
- On November 3, 1977, while in New York, Morales obtained medical certificates confirming he had an ear infection, which he argued necessitated an earlier return to Manila.
- After arriving in Paris, Stockholm, and Copenhagen, Morales requested to alter his travel plans to shorten his trip due to his medical condition. However, he was informed that such changes required confirmation from Air France's Manila office.
Denial of Rerouting
- Despite efforts to reroute his journey, including multiple requ