Case Summary (G.R. No. L-31150)
Event Overview
In March 1965, the respondents sought the assistance of Tirso Reyes, the manager of a Philippine Travel Bureau branch, to plan a world tour. Reyes submitted a tentative itinerary comprising thirty-five segments, three of which were to be operated by KLM. The respondents expressed interest in traveling to Lourdes, France, deciding on a Barcelona-Lourdes route serviced solely by Aer Lingus. They subsequently approved their itinerary and asked Reyes to make reservations. KLM issued tickets for the entire trip, including a segment for Aer Lingus, marked "RQ" indicating it was on request.
Incident Description
Upon arrival in Barcelona on June 22, 1965, the respondents checked in as directed but were off-loaded from their flight while their daughter and niece boarded. The incident was characterized by disrespectful treatment from the Aer Lingus manager, which caused the respondents emotional distress. They were forced to take a train to Lourdes, incurring additional expenses due to inadequate clothing and discomfort during the trip.
Legal Proceedings and Initial Ruling
On March 17, 1966, the respondents filed a complaint against KLM in the Court of First Instance of Manila, seeking damages for breach of contract and the humiliation suffered. The trial court ruled in favor of the respondents, awarding actual damages, moral damages, exemplary damages, and attorney's fees. Both parties subsequently appealed the decision to the Court of Appeals.
Court of Appeals Decision
On August 14, 1969, the Court of Appeals upheld part of the trial court’s ruling, affirming the award of actual damages and significantly increasing the moral damages and attorney's fees. KLM appealed this ruling, contending that it should not be held liable for the conduct of Aer Lingus by virtue of contractual limitations specified in the tickets issued to the respondents.
KLM's Arguments
KLM's defense rested on the assertion that the air tickets stipulated inclusion of the Warsaw Convention, which limits carrier liability. KLM argued that according to Article 30 of the Convention, liability should be confined to the actions occurring on its routes, and since the incident involved Aer Lingus, it should not be held accountable. KLM further contended that it acted merely as a ticket-issuing agent, thereby limiting its obligations and liabilities under the terms printed in small letters on the tickets.
Respondents' Counterarguments
The respondents countered KLM’s claims by asserting that the case did not involve an accident or delay as defined by the Warsaw Convention but rather willful misconduct. They argued that the small print on the ticket's conditions was unacceptable and that the overall journey represented a single operation. The respondents emphasized that the legal contract existed solely between them and KLM, which retained the responsibility to ensure the performance of all segments of the journey, including those operated by subcontractors like Aer Lingus.
Affirmation of Judgment
The Supreme Court upheld the Cou
...continue readingCase Syllabus (G.R. No. L-31150)
Case Overview
- This case involves an appeal by Koninklijke Luchtvaart Maatschappij N.V. (KLM Royal Dutch Airlines) against the Court of Appeals' award of damages to spouses Rufino T. Mendoza and Consuelo T. Mendoza.
- The underlying issue is centered on the respondents being denied boarding on an Aer Lingus flight while traveling as part of a world tour arranged through a travel agency.
Background Facts
- In March 1965, the respondents consulted with Tirso Reyes, manager of the Philippine Travel Bureau, regarding a world tour for themselves and their children.
- After discussing various options, they settled on a tentative itinerary that included segments on different airlines, with significant portions to be flown via KLM.
- The respondents expressed a desire to visit Lourdes, France, and chose the Barcelona-Lourdes route serviced only by Aer Lingus.
- Following their approval of the itinerary, KLM issued tickets for their entire trip, although the Aer Lingus segment was marked "RQ" (on request).
Incident Details
- After a series of travels, the respondents arrived at Barcelona airport on June 22, 1965, for their Aer Lingus flight to Lourdes.
- Despite checking in and receiving initial acceptance, the respondents were off-loaded by the Aer Lingus manager, who displayed rude and aggressive behavior.
- Their companions were allowed to board while the respondents were denied passage and subsequently had to travel by train to Lourdes, facing discomfort and additional expenses.
Legal Proceedings
- On March 17, 1966, the r