G.R. No. L-57339. December 29, 1983.
AIR FRANCE, petitioner, vs. HONORABLE COURT OF APPEALS, JOSE G. GANA (Deceased), CLARA A. GANA, RAMON GANA, MANUEL GANA, MARIA TERESA GANA, ROBERTO GANA, JAIME JAVIER GANA, CLOTILDE VDA. DE AREVALO, and EMILY SAN JUAN, respondents.

FACTS

Private respondents, the Gana family, purchased nine “open-dated” Air France tickets for a Manila/Osaka/Tokyo/Manila route in 1970, valid until May 8, 1971. They did not depart on their initially booked date. In January 1971, Jose Gana sought an extension of the tickets’ validity through intermediaries. Air France informed them that extension required payment of fare differentials due to increased exchange rates and travel tax, which the Ganas did not pay. Nevertheless, they scheduled their departure for May 7, 1971, one day before expiration. On the morning of departure, their intermediary, travel agent Lee Ella, again stated extension was impossible and warned that while they could commence travel, the tickets would be invalid for subsequent segments after expiry. Ella, on his own, attached validating stickers for the Osaka/Tokyo flight from other airlines without Air France’s knowledge or consent.
The Ganas departed for Osaka on May 7, 1971, on Air France. However, for their subsequent Osaka/Tokyo flight on May 17, Japan Airlines refused to honor the expired tickets, forcing them to purchase new tickets. Air France also refused their Tokyo/Manila return tickets. They returned to Manila on separate dates only after prepayment of adjusted fares. The Ganas sued Air France for damages from breach of contract of carriage. The trial court dismissed the complaint, but the Court of Appeals reversed and awarded moral damages.

ISSUE

Whether Air France committed a breach of contract of carriage entitling the Gana family to an award of damages.

RULING

No. The Supreme Court reversed the Court of Appeals and reinstated the trial court’s dismissal of the complaint. The legal logic centers on the terms of the contract and the Ganas’ own actions. Under applicable International Air Transportation Association (IATA) rules, a ticket is valid for one year from the commencement of the journey. The passenger must depart on the final segment before the expiry date. The tickets here expired on May 8, 1971. The Ganas, despite clear warnings from their agent about the consequences, chose to begin travel on May 7, knowing the tickets would be invalid for the remaining segments after expiration.
Air France did not breach the contract. Its refusal to honor the tickets for travel after their validity period was a rightful enforcement of the contract’s terms. The validating stickers affixed by travel agent Ella without Air France’s authority could not legally extend the ticket’s validity; they merely indicated flight reservations. Air France’s personnel allowing the Ganas to board the initial Manila/Osaka flight did not constitute ratification of Ella’s unauthorized acts, as the departure occurred before the expiry date, and the understanding was that “other arrangements” were needed for later segments. The Ganas assumed the risk of their predicament by insisting on using tickets on the eve of their expiration. Consequently, no basis exists for an award of damages against Air France.