Case Summary (G.R. No. 6801)
Factual Background
On February 14, 1978, petitioners, having confirmed first-class bookings for SAS Flight SK 893, arrived at Manila International Airport at approximately 2:35 PM, well in advance of their flight scheduled for 3:50 PM. Upon reaching the check-in counter, they encountered delays, and despite confirming their bookings through their travel agency, they were informed at around 3:10 PM that no seats were available as they had checked in after the flight manifest had closed. They contested this situation, asserting they had arrived on time but were ultimately denied boarding.
Trial Court Proceedings
The Regional Trial Court in Makati ruled in favor of the petitioners on August 24, 1988, awarding significant moral and exemplary damages along with attorney’s fees. The court's ruling was based on its finding that the airline had acted in bad faith by failing to accommodate the petitioners despite their confirmed reservation. The initial trial court judgment was amended to increase the moral damages awarded to the petitioners following a motion for reconsideration filed by them.
Appeal to the Court of Appeals
SAS filed an appeal against the trial court’s decision, arguing that the petitioners did not meet the necessary conditions for boarding since they checked in after the closing of the flight manifest. On January 21, 1997, the Court of Appeals overturned the trial court's ruling, attributing the incident of the denial of boarding to the petitioners’ late arrival instead of any fault on the part of SAS. The appellate court deemed the petitioners' testimonies as self-serving and concluded there was no sufficient evidence to substantiate their claims regarding timely check-in.
Supreme Court Analysis
In reviewing the petition, the Supreme Court found no merit in the allegations lodged by the petitioners against the appeal court’s decision. It noted that contracts for air carriage create a duty for the airline, yet it underscored that such a contract differs in nature from typical contractual obligations due to the airline's duty to the public. The Court determined that for an award of moral damages to be justified, evidence must show that the breach was committed fraudulently or in bad faith. Since the evidence indicated that the petitioners’ failure to board was strictly due to their own tardiness at check-in, the Court resolved that the airline had acted within reason.
Findings on Damages
The Court emphasized that moral damages are typically not recoverable in cases of breach of contract unless bad faith is evident. Furthermore, it clarified that merely being denied boarding does not automati
...continue readingCase Syllabus (G.R. No. 6801)
Case Overview
- Petitioners Collin A. Morris and Thomas P. Whittier filed a complaint for damages against Scandinavian Airlines System (SAS) for breach of contract of air carriage after being bumped off their confirmed flight, SK 893, from Manila to Tokyo on February 14, 1978.
- The trial court initially ruled in favor of the petitioners, awarding them moral damages, exemplary damages, and attorney's fees.
- The Court of Appeals later reversed this decision, leading to the current appeal by the petitioners.
Background of the Case
- On February 14, 1978, petitioners were to travel from Manila to Tokyo for business meetings.
- They had a confirmed booking in the first-class section of SAS Flight SK 893, scheduled to depart at 3:50 PM.
- They arrived at the airport at approximately 2:35 PM, but encountered delays at the check-in counter and were ultimately denied boarding.
Events Leading to the Denial of Boarding
- Petitioners were picked up by a limousine service from their residences and arrived at the Manila International Airport at around 2:35 PM.
- After clearing customs, they approached the SAS check-in counter at approximately 3:10 PM, only to be informed that there were no available seats despite their confirmed booking.
- The check-in counter was closed by the time they arrived, and their names had been marked as "NO SHOW" on the fl