G.R. No. 160739 - Mangila vs. Pangili

Case Summary (G.R. No. 160739)

Key Dates

Flight and incident: May 8, 1988 (PR 178, scheduled 7:10 a.m.). Relevant procedural dates include trial testimony in 1989–1990, Court of Appeals decision dated August 12, 1996, denial of motion for reconsideration dated November 15, 1996, and Supreme Court decision dated December 8, 2003. (Applicable constitutional framework: 1987 Philippine Constitution, given decision date after 1990.)

Applicable Law and Legal Principles Recognized

Contract of carriage obligations of common carriers and the heightened duty of diligence in air carriage (decisional law cited in the record).
Exceptions to appellate deference to factual findings: grave abuse of discretion; findings premised on speculation, surmise or conjecture; manifestly mistaken inferences; misapprehension or conflict of facts; overlooked undisputed facts, among others.
Article 2199, Civil Code — actual/compensatory damages require competent proof of pecuniary loss.
Principles on moral and exemplary damages: moral damages must be proximate result of wrongful act and be proportional to suffering; exemplary damages require proof warranting moral/compensatory damages first; overbooking and accommodating non‑revenue passengers can amount to bad faith.

Procedural History

Regional Trial Court (RTC), Branch 53, Sorsogon: complaint for damages by private respondents against PAL; RTC rendered judgment ordering reimbursement of ticket purchases and sizable awards of actual, moral and exemplary damages, attorney’s fees, incidental expenses, and costs. Court of Appeals: affirmed the RTC decision in toto and denied PAL’s motion for reconsideration. Supreme Court: PAL filed a Rule 45 petition for review on certiorari challenging factual findings and damages awards.

Core Factual Findings Made by the Trial Court and Affirmed by the CA

Plaintiffs purchased confirmed tickets for PR 178 (Judy, infant Gian Carlo, and Jane). A separate ticket was purchased for Dra. Emily Chua which plaintiffs sought to transfer to minor Carlo Benitez.
Plaintiffs arrived at Legaspi Airport at approximately 6:20 a.m. for a 7:10 a.m. departure. Salvador Gonzales tendered the tickets at the check‑in counter and observed an annotation later read as “late check‑in 7:05.” Lloyd Fojas handled the tickets and instructed payment arrangements; plaintiffs were ultimately not permitted to board. The aircraft departed at about 7:30 a.m. (20 minutes late).
PAL accommodated non‑revenue/go‑show/waitlisted passengers and had overbooked PR 178. Manuel Baltazar, after evaluating the flight manifest, testified to confirmed passenger totals and overbooking exceeding permissible levels. Fojas acknowledged he could not recall the number of boarding passes issued to non‑revenue or waitlisted passengers and confirmed management had authority to issue boarding passes to such passengers.

Supreme Court’s Standard on Review of Findings of Fact

The Court reiterated the general rule that factual findings of the RTC and CA are binding except under established exceptions (e.g., findings based on conjecture or when appellate court misapprehended facts). The Court applied those standards and emphasized respect for trial court determinations of witness credibility where no grave abuse or palpable error was shown.

Credibility and Weight of Evidence

The Supreme Court found the testimonies of private respondents (Judy Amor, Salvador Gonzales, Atty. Owen Amor) and Manuel Baltazar to be consistent and corroborative, and therefore entitled to probative weight. PAL’s lone witness, Lloyd Fojas, lacked sufficient quality to overcome the respondents’ proof; his inability to recall critical issuance details undermined PAL’s position. The Court rejected PAL’s contention that Baltazar’s familial relation or alleged disgruntlement rendered his testimony inadmissible or inherently unreliable, noting the absence of proof of bias and the general principle that relationship alone does not ipso facto discredit testimony.

Findings on Bumping, Overbooking, and Breach of Contract of Carriage

Based on manifest exhibits and witness testimony, the Court found that confirmed passengers (including respondents) were denied boarding in favor of non‑revenue/waitlisted passengers and that PR 178 was overbooked beyond permissible limits. The Court characterized overbooking and accommodating non‑revenue passengers at the expense of confirmed, fare‑paying passengers as conduct amounting to bad faith in breaching the contract of carriage, given the public‑character nature and heightened duty of common carriers in air transport.

Ruling on Whether Respondents Were Late for Check‑in

The Supreme Court affirmed the RTC and CA finding that respondents were not late: they arrived at the airport at about 6:20 a.m., and the CA appropriately credited respondent testimony over PAL’s lone contrary account. The Court declined to reweigh credibility absent strong grounds to disturb the lower courts’ assessments.

Actual (Compensatory) Damages — Analysis and Modification

The Supreme Court found the RTC’s award of P100,000 as “actual damages” to all private respondents unsupported by competent proof: Article 2199 requires pecuniary loss proved by evidence. The only proven pecuniary losses were the ticket purchase prices for Judy, Jane and Gian. The Court reduced actual damages to P978.60 (P466.00 each for Judy and Jane; P46.60 for infant Gian), payable to Judy Amor, and dismissed the complaint of Carlo Benitez for lack of cause of action because the ticket purportedly in his name (Exhibit C) lacked flight/time detail and ticket transferability was expressly prohibited.

Moral Damages — Analysis and Modification

The Court recognized entitlement to moral damages for Judy Amor because the carrier’s bad faith in overbooking and accommodating non‑revenue passengers proximately caused mental anguish and other non‑pecuniary injury. However

Case Syllabus (G.R. No. 160739)

Case Caption, Citation and Procedural Posture

G.R. No. 127473; Decision dated December 08, 2003 by the Supreme Court, Second Division; penned by Justice Austria‑Martinez; concurred in by Justices Puno (Chairman), Quisumbing, Callejo, Sr., and Tinga.
Petition for review on certiorari under Rule 45 by Philippine Airlines, Inc. (petitioner) seeking reversal of the Court of Appeals decision dated August 12, 1996 (CA‑G.R. CV No. 38327) and the November 15, 1996 resolution denying petitioner’s motion for reconsideration.
Originating complaint: Civil Case No. 5390 filed with the Regional Trial Court, Branch 53, Sorsogon, Sorsogon by private respondents Judy Amor, Jane Gamil, minor Gian Carlo Amor (represented by Atty. Owen Amor), and minor Carlo Benitez (represented by Josephine Benitez) for damages allegedly caused by petitioner’s failure to honor confirmed tickets.

Facts — Chronology and Core Events

Private respondent Judy Amor purchased three confirmed tickets at Philippine Airlines’ Legaspi City branch for flight PR 178 scheduled May 8, 1988, 7:10 a.m., bound for Manila, for herself, her infant son Gian Carlo Amor, and her sister Jane Gamil.
A fourth ticket purchased for Dra. Emily Chua was intended to be used by minor Carlo Benitez after Dra. Chua backed out.
Judy, Gian, Jane and Carlo arrived at Legaspi Airport at approximately 6:20 a.m. on May 8, 1988, accompanied by Atty. Owen Amor and Salvador Gonzales.
Salvador Gonzales fell in line at the check‑in counter; while he waited with four persons ahead of him and three behind, Lloyd Fojas (check‑in clerk) called him to the counter and wrote on the tickets what Gonzales later read as “late check‑in 7:05.”
When Gonzales presented the tickets (at or read as 7:05 a.m.), Fojas informed him they were late, wrote “late check‑in 7:05” on the tickets and instructed him to proceed to the cashier to make arrangements; Fojas allegedly told Atty. Owen Amor to go to his supervisor for re‑booking because boarding was about to commence.
Private respondents were not able to board PR 178; the plane departed at about 7:30 a.m., twenty minutes behind schedule.
Private respondents sought bus transport to Manila, found none, returned to the airport and attempted to catch an afternoon flight.
Flight PR 278 scheduled 2:30 p.m. was cancelled allegedly due to “aircraft situation.”
Private respondents were told to wait for PR 180 at 5:30 p.m.; they checked in bags and tendered tickets but were informed at the counter they could not be accommodated; boarding passes inserted in their tickets and luggage tags were removed (at least in part by Fojas).
Manuel Baltazar, former Acting Manager of PAL in Legaspi (May 1988), testified that confirmed passengers, including private respondents, were not able to board PR 178 because non‑revenue, “go‑show,” or waitlisted passengers were accommodated and that there was overbooking for PR 178.

Parties’ Contentions on Appeal

Petitioner (PAL):
- Asserts private respondents were late in checking in for PR 178 and thus not entitled to damages.
- Maintains private respondents were only chance/waitlisted passengers for PR 180 and were not accommodated because confirmed passengers had checked in.
- Argues awards of actual, moral and exemplary damages have no factual or legal basis; denies bad faith or malice; contends it exerted efforts to assist respondents (protective bookings, etc.).
- Warns that awarding damages for late check‑in would reward breach of contract and encourage intentional late check‑ins.
- Asserts moral/exemplary damages and attorney’s fees are not recoverable absent fraud, malice or bad faith.
- Challenges credibility of adverse witnesses, particularly Baltazar (alleged disgruntled former employee and relative of respondents).
Private Respondents:
- Insist they checked in on time; trial court findings and CA affirmation are supported by preponderance and quality of evidence.
- Argue petitioner accommodated non‑revenue/go‑show/waitlisted passengers, overbooked the flight, and acted in a high‑handed and malicious manner causing mental anguish, public contempt, sleeplessness and other moral suffering; defend reasonableness of damages awarded.
- Emphasize trial court’s superior position to assess credibility; note petitioner’s witness Fojas corroborated that non‑revenue/waitlisted passengers were sometimes accommodated.

Evidence and Witness Testimony Presented

Private respondents’ witnesses and key facts:
- Judy Amor: testified arrival time (6:20 a.m.), purchase prices of tickets (P466.00 each for Judy and Jane; P46.60 for infant Gian), attempts to secure accommodation, statement that others were complaining to station manager (Delfin Canonizado) because they were not accommodated; testified she missed part of the Philippine Dental Association convention and suffered embarrassment and inconvenience.
- Salvador Gonzales: testified to sequence at check‑in counter, Fojas writing on tickets and handling of tickets.
- Atty. Owen Amor: corroborated sequence of events at airport and attempts to plead with PAL employees.
- Manuel Baltazar (former Acting Manager): testified after reviewing manifest that there were non‑revenue passengers accommodated and that confirmed passengers were bumped off; testified manifest showed a total of 126 confirmed passengers on a 109‑seat aircraft, indicating overbooking beyond allowable 10% (manifest and testimony referenced).
Petitioner’s witness:
- Lloyd Fojas (check‑in clerk): testified Gonzales tendered tickets at 7:05 a.m. when the counter was closed, wrote “late check‑in 7:05” on tickets, checked‑in allowed only until 30 minutes before departure (i.e., until 6:40 a.m. for a 7:10 a.m. flight), stated passengers were already proceeding to the plane and baggage loaded; on cross‑examination, Fojas could not recall how many waitlisted or non‑revenue passengers were accommodated for PR 178 or PR 180 and acknowledged management had authority to issue boarding passes to non‑revenue passengers.

Trial Court (RTC) Judgment — Dispositive Relief Rendered

The Regional Trial Court found for private respondents and ordered, in it
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