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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