GR 129988; (July, 2003) (Digest)
G.R. No. 129988 ; July 14, 2003
CHINA AIRLINES, LTD., petitioner, vs. COURT OF APPEALS, ANTONIO S. SALVADOR and ROLANDO C. LAO, respondents.
FACTS
Private respondents Antonio Salvador and Rolando Lao planned to travel to Los Angeles on June 13, 1990. Initially booked through Morelia Travel Agency with China Airlines (CAL), they later engaged American Express Travel Service (Amexco) after finding lower rates. On June 11, Lao provided Amexco with the record locator number CAL had issued to Morelia. Amexco called CAL, used this number, and successfully confirmed the reservation, issuing confirmed tickets. That same afternoon, however, CAL called Morelia to reconfirm; upon being informed, Morelia cancelled the booking. Consequently, on the day of the flight, CAL prevented private respondents from boarding as their names were not on the manifest.
Private respondents filed a complaint for damages against CAL and Amexco, alleging that the one-day delay caused them to lose business opportunities. The Regional Trial Court ruled in their favor, awarding moral and exemplary damages and attorney’s fees, a decision affirmed by the Court of Appeals. CAL elevated the case to the Supreme Court.
ISSUE
Whether petitioner China Airlines is liable for damages for unjustifiably refusing to honor the confirmed reservations of private respondents.
RULING
Yes, but the award of damages is modified. The Supreme Court found CAL liable for breach of contract. A contract of air carriage was perfected when CAL confirmed the booking made by Amexco and issued the corresponding tickets. CAL’s subsequent cancellation, based solely on Morelia’s advice after confirmation had already been given to a different agent, was unjustified. CAL, as the assignor of the unique record locator number, had the means and duty to verify and manage its booking system properly. Its failure to do so constituted negligence.
However, the Court deleted the awards for moral and exemplary damages. Private respondents failed to prove that CAL acted with fraud, bad faith, or wanton disregard of their rights. The element of willful injury or deliberate wrong necessary for such damages was absent. The fact that CAL called Morelia to reconfirm, while negligent, did not in itself constitute bad faith. Consequently, the Court awarded nominal damages of P5,000.00 to each private respondent. Nominal damages are adjudicated to recognize a violation of a legal right, even when no substantial loss or injury is proven, serving to vindicate a right that was unjustly infringed.