Case Summary (G.R. No. 91332)
Facts of the Case
In October 1981, the petitioners purchased three round-trip airline tickets from Northwest Airlines, Inc. for travel from the U.S. to Manila and back. Each ticket was handwritten by the airline’s sales agent, indicating a departure time of 10:30 A.M. on January 17, 1982, for their return flight. The petitioners arrived at the airport at 9:15 A.M., 75 minutes ahead of the scheduled departure, but were informed that there was no available accommodation on the flight as it had already taken off at 9:15 A.M., indicating an erroneous entry in their tickets. They had previously confirmed their reservations, and their names were included in the passenger manifest for Flight 002.
Legal Proceedings and Initial Judgment
Due to the distress caused by being bumped off their flight, the petitioners filed for damages against the airline in the Regional Trial Court of Manila. The trial court ruled in their favor on July 2, 1985, awarding actual, moral, exemplary, and nominal damages, totaling substantial amounts, alongside attorney's fees.
Appeal and Court of Appeals Decision
The private respondent appealed the decision to the Court of Appeals, which rendered its judgment on June 20, 1989. The appellate court found the petitioners had complied with the "72-hour reconfirmation rule" and affirmed the trial court's finding of gross negligence by the airline. However, it significantly reduced the moral damages and provided reasoning that the petitioners had not taken the witness stand to provide personal testimony regarding their suffering, which could impact the damages awarded.
Supreme Court Interpretation
The matter was further elevated to the Supreme Court through legal petitions from both respondents and petitioners. The Supreme Court re-evaluated the appellate court’s rationale for denying moral damages and acknowledged precedents whereby damages could be awarded for gross negligence that amounted to malice or bad faith, irrespective of the absence of direct testimony from the affected parties.
Final Ruling
The Supreme Court concl
...continue readingCase Syllabus (G.R. No. 91332)
Case Overview
- This case revolves around petitioners Dr. Herman Armovit, Mrs. Dora Armovit, and Miss Jacqueline Armovit, a family residing in the United States, who faced issues with their return flight to the U.S. from the Philippines during a Christmas visit.
- The central issue arose when they were bumped off their flight due to an erroneous entry on their plane tickets regarding the time of departure.
Background of the Case
- The petitioners purchased three round-trip tickets from Northwest Airlines, Inc. for their travel home to the Philippines.
- The tickets indicated a departure time of 10:30 A.M. on January 17, 1982, from Manila to Tokyo, although the actual scheduled flight was at 9:15 A.M.
- Upon arriving at the Manila International Airport at 9:15 A.M., they were informed that the flight had already taken off.
Details of the Incident
- The petitioners had reconfirmed their flight reservations through a representative, Ernesto Madriaga, prior to departure, but the erroneous time on the tickets remained unchanged.
- Dr. Armovit expressed significant anger and frustration at being denied boarding, as they missed important appointments in the U.S. due to the situation.
- The family experienced emotional distress, anxiety, and financial losses while waiting for the next available flight.
Legal Proceedings
- Following the incident and the a