G.R. No. 182395. October 05, 2015 (Case Brief / Digest)

**Title:** Marito T. Bernales vs. Northwest Airlines

Marito T. Bernales, a lawyer, university dean, and board member of the Sangguniang Panlalawigan of Camarines Sur, was part of a delegation traveling to Honolulu, Hawaii, for a trade and tourism mission on October 1, 2002, aboard Northwest Airlines (NWA) Flight No. 10. Upon arrival in Narita, Japan, their connecting flight to Honolulu was canceled due to a typhoon, alongside most flights. NWA then attempted to accommodate passengers on a later flight, Flight No. 22, rescheduled for the same night. Bernales, last in the economy class waitlist, was initially denied boarding due to seat unavailability but was eventually given a “dummy” boarding pass and made it onto the flight, only to face a seat dispute and later, delay as the flight missed the airport’s extended curfew.

Stranded at Narita Airport with over 1,500 other passengers due to fully booked nearby hotels, Bernales and others spent the night there. They were given blankets, snacks, and water. The next day, they chose to fly to Los Angeles on way to Honolulu, missing their scheduled appointments in Hawaii.

Bernales filed a complaint against NWA for breach of carriage contract, seeking moral and exemplary damages for the mistreatment he allegedly experienced, including being shouted at and physically removed from the shuttle by an NWA agent, the embarrassment from being reseated, and discomfort of spending the night at the airport.

The case went through the Regional Trial Court (RTC) of Iriga City, which ruled in favor of Bernales, awarding him substantial damages. However, the Court of Appeals (CA) reversed this decision, leading Bernales to file a petition with the Supreme Court of the Philippines.

1. Whether the CA erred in its application of the law concerning awards for moral and exemplary damages in cases of breach of contract of carriage.
2. Whether NWA acted in bad faith when they attempted to accommodate passengers affected by the flight cancellations.
3. Whether the testimonies regarding the alleged mistreatment of Bernales by NWA personnel were credible.

**Court’s Decision:**
The Supreme Court noted that factual findings of the CA are generally conclusive, except in specific circumstances that did not apply to this case. It found that:
– Moral damages in contract breaches, like those in carriage contracts, are only applicable in cases of passenger death or instances where the carrier acted in fraud or bad faith.
– The typhoon was a fortuitous event, absolving NWA of direct fault for the cancellation and subsequent inconvenience, evidenced by their effort to transport passengers on the next available flight.
– The behavior of NWA personnel, as described by Bernales, lacked corroboration and was contradicted by the personnel’s commendable service record.
– NWA could not be held responsible for the discomfort suffered by Bernales and other passengers at Narita Airport, as it was an outcome of the typhoon and impacted all stranded passengers equally.
– Given these factors, the court affirmed the CA’s decision to dismiss Bernales’s complaint.

The decision reiterated the doctrine that moral damages resulting from a breach of a contract of carriage are recoverable only in cases where the mishap results in the passenger’s death or where the carrier is guilty of fraud or bad faith, underscoring the distinction between bad faith and mere negligence or failure to fulfill contractual obligations due to unforeseeable events.

**Class Notes:**
– Breach of a contract of carriage and awards of moral and exemplary damages require a demonstration of fraud or bad faith by the carrier.
– Fortuitous events, such as natural disasters, absolve carriers from liability for resulting non-performance of contractual obligations.
– Discrepancies in testimonial evidence and the credibility of witnesses are key in determining the outcome of claims relating to personal mistreatment and service failures.
– Legal recourses and compensation for passengers inconvenienced by flight cancellations due to uncontrollable circumstances like weather conditions are limited and defined by evidence of the carrier’s intent and efforts to mitigate the situation.

**Historical Background:**
This case highlights the legal and operational challenges airlines and passengers face during natural disasters, tying into broader discussions on the limits of liability and the responsibilities of carriers under the contract of carriage. It underscores the balance courts seek between consumer protection and acknowledging circumstances beyond the control of service providers.


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