Case Summary (G.R. No. 151258)
Key Dates
- March 28, 1958: Issuance of “First Class” round‐trip ticket from Manila to Rome via Lourdes.
- March 30, 1958: Departure from Manila as part of a group of Filipino pilgrims.
- August 28, 1966: Decision of the Supreme Court of the Philippines.
Applicable Law
- 1935 Philippine Constitution, Article VIII, Section 12 (requirement for clear findings of facts and law).
- Rules of Court: Rule 36 (Section 1), Rule 45 (Section 2), Rule 51 (Section 4).
- Civil Code (pre-1987): Articles 21 (willful injury), 2180 (employer liability), 2229 (moral damages), 2232 (exemplary damages), 2208 (attorneys’ fees).
Factual Background
Carrascoso paid for and received a confirmed first‐class ticket. He traveled first‐class from Manila to Bangkok. At Bangkok, the airline’s manager forcibly removed him from his seat to accommodate another passenger, compelling him to occupy tourist class despite his confirmed entitlement. An accompanying purser recorded in his notebook that Carrascoso “was forced to go to the tourist class against his will, and that the captain refused to intervene.”
Procedural History
The trial court awarded Carrascoso moral damages (P25,000), exemplary damages (P10,000), fare differential (P393.20), attorneys’ fees (P3,000), interest, and costs. The Court of Appeals affirmed the judgment with slight adjustment to the fare refund (P383.10) and sustained all other awards. Air France sought certiorari review before the Supreme Court, challenging factual findings, entitlement to first‐class accommodation, and damage awards.
Sufficiency of Findings
Air France contended the Court of Appeals failed to make complete findings on all factual issues. Under the 1935 Constitution and Rules of Court, only “essential ultimate facts” must appear. A decision need not recount every piece of evidence or every defense contention. Here, the appellate decision sufficiently identified the determinative facts—confirmation of a first‐class ticket, wrongful ouster, and resultant injuries—satisfying constitutional and statutory mandates.
Certiorari Review Limited to Questions of Law
Under Rule 45, only questions of law may be raised on certiorari from a CA decision. Factual findings of the appellate court are conclusive. This Court may not reweigh evidence or disturb factual determinations unless no evidence supports them.
Right to First‐Class Seat Under Contract
Air France argued the ticket did not guarantee first‐class seating absent confirmed reservation at each stop. Both courts, however, credited documentary evidence and testimony establishing confirmation. The issuance of a ticket paid at first‐class rates and marked “O.K.” for confirmed space was held to impose a binding obligation on the carrier to honor that seat.
Bad Faith and Moral Damages
Carrascoso’s complaint alleged breach of contract, forced removal, and resulting humiliation, mental anguish, and wounded feelings. Although the complaint did not use the term “bad faith,” the circumstances implied it. The CA found that the manager’s forcible ejection amounted to bad faith—an affirmative wrongful act contrary to morals and social conventions—entitling Carrascoso to moral damages.
Employer Liability for Employee Acts
Under Civil Code Article 2180, an employer is liable for the willful misconduct of its employees. The manager’s intentional ouster of Carrascoso constituted a tortious act. Air France, as employer, therefore bore responsibility for the moral injury inflicted.
Exemplary Damages
Article 2232 authorizes exemplary damages where the defendant’s conduct is wanton, reckless, oppressive, or malevolent. The manager’s arbitrary and humiliating expulsion of a ticketed passenger met this standard, justifying an award of exemplary damages in addition to moral damages.
Attorneys’ Fees
Article 2208 empowers the court to award attorneys’ fees when exemplary damages are granted. Both lower courts exercised this discretion, awarding P3,000.00, which
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Procedural History
- The Court of First Instance of Manila rendered judgment in Civil Case No. 38810, ordering Air France to pay Carrascoso ₱25,000.00 as moral damages, ₱10,000.00 exemplary damages, ₱393.20 fare difference (Bangkok–Rome segment) with interest from complaint filing, ₱3,000.00 attorneys’ fees, and costs.
- On appeal (C.A.-G.R. No. 26522-R), the Court of Appeals reduced the fare difference award from ₱393.20 to ₱383.10, affirmed all other reliefs, and taxed costs against petitioner.
- Petitioner filed a petition for certiorari before the Supreme Court, challenging the completeness of the Court of Appeals’ findings of fact and urging the Court to review factual determinations and overturn the judgment.
Facts of the Case
- Carrascoso, a civil engineer, joined 48 Filipino pilgrims departing Manila for Lourdes on March 30, 1958.
- On March 28, 1958, Philippine Air Lines, Inc., as Air France’s agent, issued Carrascoso a confirmed first class round-trip ticket Manila–Rome.
- Carrascoso travelled first class from Manila to Bangkok. At Bangkok, Air France’s Manager ordered him to vacate his first class seat for a “white man,” despite his refusal and protest (“…over my dead body…”).
- A commotion ensued; fellow Filipino passengers intervened, and Carrascoso reluctantly moved to tourist class.
- The purser, in Carrascoso’s hearing, noted in his French-language notebook: “First-class passenger was forced to go to the tourist class against his will, and the captain refused to intervene.”
Petitioner's Grounds for Certiorari
- Petitioner asserted the Court of Appeals failed to make “complete findings of fact on all issues properly raised,” in violation of:
• Section 12, Article VIII of the Constitution (decisions must state facts and law clearly).
• Section 1, Rule 36 and Section 4, Rule 51 of the Rules of Court (judgments and appellate decisions require clear, complete factual findings). - Petitioner sought review of all factual findings, urging this Court to reassess evidence and overturn the lower courts’ conclusions.
Findings of the Court of Appeals
- The Court of Appeals found Carrascoso held a valid first class ticket and was entitled to first class accommodations.
- It rejected Air France’s argument that first class carriage depended on seat availability or confirmation at each stop.
- It credited Carrascoso’s testimony and Exhibits A–C showing “O.K.” marks on tickets, confirmed for first class.
- It found that the Manager of Air France in Bangkok acted in bad faith by ousting Carrascoso to accom