G.R. No. 179117; February 3, 2010
NORTHWEST AIRLINES, INC., Petitioner, vs. SPOUSES EDWARD J. HESHAN AND NELIA L. HESHAN AND DARA GANESSA L. HESHAN, REPRESENTED BY HER PARENTS EDWARD AND NELIA HESHAN, Respondents.

FACTS

In July 1998, Edward Heshan purchased three roundtrip tickets from Northwest Airlines for himself, his wife Nelia, and their daughter Dara for travel from Manila to St. Louis, Missouri, USA, and back. After Dara’s ice skating competition ended on August 7, 1998, the Heshans proceeded to the airport for their connecting flight from St. Louis to Memphis. They checked in their luggage early and were at the boarding area on time. At the check-in counter, Edward was asked to step aside and wait after presenting the tickets. After other passengers were given boarding passes, the Heshans were told to board the plane without boarding passes and to occupy open seats. Inside the plane, only one regular passenger seat was available, offered to Dara, while Edward and Nelia were directed to occupy two “folding seats” at the rear, which they believed were crew seats. Upset, they complained and were told they could disembark if dissatisfied. They chose to disembark. The plane departed without them. They were later endorsed to another airline to reach Los Angeles, arriving late and having to wait for their luggage. On September 24, 1998, they demanded indemnification for breach of contract of carriage. Northwest Airlines replied that they were prohibited from boarding due to “verbally abusing [the] flight crew.” The Heshans filed a complaint for breach of contract with damages. The Regional Trial Court ruled in favor of the Heshans, awarding moral damages, exemplary damages, attorney’s fees, and costs. The Court of Appeals affirmed but reduced the damages. Northwest Airlines filed a petition for review.

ISSUE

Whether the Court of Appeals erred in ruling that respondents were entitled to moral damages, exemplary damages, and attorney’s fees, and in awarding excessive damages.

RULING

The Supreme Court denied the petition. The issues raised were predicated on factual questions, and in petitions for review, only questions of law may be raised. The factual findings of the appellate court, which were in complete accord with the trial court, are generally binding. The trial court found the Heshans’ version more credible. Northwest Airlines failed to present documentary evidence such as the flight manifest and seating capacity to refute the claims, and its failure to do so led to an inference that such evidence would be adverse to its case. The airline also failed to satisfactorily explain why it did not issue boarding passes to confirmed passengers who checked in on time. The Court found that Northwest Airlines committed a breach of contract of carriage. The award of damages was sustained, with the Court noting that the amounts awarded by the appellate court (₱2 million moral damages and ₱300,000 exemplary damages) were in line with jurisprudence. The petition was denied for lack of merit.