Case Summary (G.R. No. 88561)

Case Background

• The case involves Dr. Herman Armovit, Dora Armovit, and Jacqueline Armovit (petitioners) against Northwest Airlines, Inc. and the Court of Appeals (respondents).
• The petitioners, a Filipino family residing in the U.S., faced issues with their flight back to the U.S. from the Philippines due to an erroneous departure time indicated on their tickets.

Factual Background

• The petitioners purchased round-trip tickets from Northwest Airlines for a holiday visit to the Philippines in December 1981.
• The tickets erroneously listed their departure flight as January 17, 1982, at 10:30 A.M., despite the flight actually departing at 9:15 A.M. on the same day.
• Upon arrival at the airport, the petitioners were informed they could not board the flight as it had already departed, leading to distress and financial losses.

Legal Proceedings

• The petitioners filed for damages in the Regional Trial Court of Manila due to the airline's breach of contract.
• The Regional Trial Court ruled in favor of the petitioners, awarding various damages, including actual, moral, exemplary, and nominal damages.

Court of Appeals Decision

• The Court of Appeals upheld some aspects of the trial court's decision but modified damage awards, particularly reducing moral damages due to a lack of witness testimony regarding emotional distress.
• The appellate court acknowledged the airline's negligence but ruled that moral damages were unwarranted since the breach was not malicious.

Supreme Court Ruling

• The Supreme Court granted the petition of the Armovits, modifying the appellate court's decision regarding damages awarded.
• The Court recognized the airline's gross negligence in confirming flight details and the emotional impact on the petitioners despite their absence in court.

Damages Awarded

• Actual Damages: Confirmed at P1,300.00.
• Moral Damages:
  • Dr. Herman Armovit: P100,000.00
  • Mrs. Dora Armovit: P100,000.00
  • Miss Jacqueline Armovit: P100,000.00
• Exemplary Damages:
  • Dr. Herman Armovit: P100,000.00
  • Mrs. Dora Armovit: P50,000.00
  • Miss Jacqueline Armovit: P20,000.00
• Attorney's Fees: 5% of the total awards.

Key Legal Principles

• Breach of Contract: The case illustrates that breaches of air transportation contracts can result in compensatory damages, including moral and exemplary damages, especially in cases of gross negligence.
• Negligence and Malice: The Court noted that gross negligence could equate to malice in certain contexts, justifying awards for emotional distress.
• Testimony and Evidence: The absence of direct testimony from the petitioners did not negate the validity of their claims, as corroborating witness testimony was deemed sufficient.

Key Takeaways

• Airlines owe a duty of care to passengers, which incl

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Case Syllabus (G.R. No. 88561)

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

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