Tuesday, January 16, 2024

Case Digest: Northwest Airlines vs. Catapang, G.R. No. 174364

 

Northwest Airlines v. Catapang, 594 SCRA 401, G.R. No. 174364, July 30, 2009

Subject: Transportation Law


FACTS

Delfin S. Catapang, a lawyer and Assistant Vice President of the United Coconut Planters Bank (UCPB), was directed by UCPB to go on a business trip to Paris, intending to proceed to the United States afterward. Catapang requested First United Travel, Inc. (FUT) to issue him a ticket allowing rebooking or rerouting within the United States. FUT, as the authorized agent of Northwest Airlines, Inc. (petitioner), issued a ticket with a rebooking/rerouting scheme for an additional fee of US$50.

Upon Catapang's arrival in New York, petitioner's office informed him that his ticket was not rebookable or reroutable. He was advised to go to petitioner's nearest branch office. Catapang visited the World Trade Center branch, where an employee informed him that his ticket was of a "restricted type" and could only be rebooked by paying an additional US$644.00. Faced with no other option, Catapang paid the amount under protest.

In response, Catapang sent a letter of demand to petitioner, seeking damages for the airline's breach of contract, mistreatment by its personnel, and the additional expenses incurred. With no response from petitioner, Catapang filed a complaint for damages with the Regional Trial Court (RTC) of Makati. The RTC found petitioner liable for breach of contract of carriage and awarded damages. The Court of Appeals affirmed the decision with modifications, reducing the award of moral damages but upholding the overall decision.

ISSUE

Whether or not Northwest Airlines, Inc. breached the contract of carriage with Delfin S. Catapang and is liable for damages.

RULING

Yes, the Supreme Court ruled in favor of respondent and held petitioner liable for breach of contract of carriage. The court found that petitioner breached the contract of carriage by not allowing respondent to rebook or reroute his flight despite the agreement made with FUT. The court also noted that petitioner's agent in New York treated respondent rudely, which further aggravated the breach. The court held that passengers have the right to be treated with kindness, respect, courtesy, and due consideration by a carrier's employees. Therefore, petitioner was held liable for damages.

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