Case Summary (G.R. No. 92740)
Facts of the Case
The respondents purchased their tickets for the flight in August 1985. The tickets contained specific check-in conditions stating that passengers must check in at least one hour prior to departure, and failure to check in at least 30 minutes before would result in forfeiture of their reservation. The respondents alleged that they arrived at the check-in counter over an hour before the flight, but no airline personnel were available to assist them until shortly before the scheduled departure. Consequently, they sought actual, moral, and exemplary damages, as well as attorney's fees, claiming breach of contract by PAL.
Trial Court Decision
The Regional Trial Court of Imus, Cavite ruled in favor of the respondents, determining that PAL was liable for breach of contract for failing to accommodate them on the flight. The court ordered PAL to pay the total value of the tickets, additional fees, and substantial damages to each respondent, alongside attorney's fees and litigation expenses.
Appeal to the Court of Appeals
PAL appealed the decision to the Court of Appeals, which affirmed the trial court's ruling. The appellate court focused on the credibility of witnesses and the circumstances surrounding the alleged late check-in of the respondents.
Legal Issues Raised
In the appeal to the Supreme Court, PAL raised two primary legal questions:
- Whether the Court of Appeals could validate its decision based solely on the credibility of witnesses without adequately considering the material evidence presented by the defense.
- Whether the award of moral and temperate damages, as well as attorney’s fees, was warranted given the preponderance of evidence.
Evaluation of Evidence
The Supreme Court emphasized that the case revolved around factual determination regarding the timing of the respondents' check-in. The preponderance of evidence standard was applied, highlighting the critical relevance of witness credibility and the absence of substantial documentary evidence from the respondents to counter PAL's assertions. The Court referenced numerous testimonies indicating that the respondents did indeed check in late, contrary to their claims that they were on time.
Findings on Check-In Timing
The evidence demonstrated that other passengers were advised of their lateness and denied boarding prior to the respondents’ arrival at the check-in counter. Testimonies established that the respondents checked in after the cut-off time, which was corroborat
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Case Overview
- The case involves a petition for review on certiorari filed by Philippine Airlines, Inc. (PAL) against Jaime M. Ramos and several other private respondents.
- The petition seeks to reverse the decision of the Court of Appeals dated March 15, 1990, which affirmed the Regional Trial Court’s ruling directing PAL to pay damages to the private respondents for breach of contract of carriage.
- The private respondents claimed they were wrongfully denied boarding on Flight No. 264 from Naga City to Manila on September 24, 1985.
Factual Background
- The private respondents held confirmed tickets for PAL Flight No. 264, scheduled to depart at 4:25 PM.
- The tickets were purchased in August 1985, which included a condition mandating check-in at least one hour prior to departure.
- The respondents alleged they checked in on time but were not accommodated due to the absence of PAL personnel at the check-in counter until shortly before departure.
Trial Court Proceedings
- The trial court found PAL liable for breach of contract due to the non-accommodation of the private respondents.
- The court ordered PAL to pay:
- Actual damages of P1,250.20 (total value of tickets)
- P22.50 for airport fees
- P20,000.00 each for moral and temperate damages
- P5,000.00 for attorney's fees and litigation expenses.
Court of Appeals Decision
- PAL appealed the decision to the Court of Appeals, which affirmed th