Air France vs. Gana et al.: A Case of Expired Airline Tickets and Alleged Breach of Contract
### Facts:
In February 1970, the Gana family purchased nine “open-dated” air tickets for a round trip from Manila to Osaka/Tokyo from Air France through Imperial Travels, Inc. The tickets were exchanged by Air France for a scheduled trip on May 8 and May 22, 1970, but were not used on those dates. In January 1971, attempts were made to extend the validity of the tickets beyond their expiration date on May 8, 1971. Teresita Manucdoc, assisting the Ganas, was informed by travel agent Lee Ella of the Philippine Travel Bureau that extension was not possible without additional payment due to fare and tax increases. Despite this, the Ganas proceeded with their trip on May 7, 1971, unknowingly using tickets that would expire during their travels. Consequently, for their flight from Osaka to Tokyo and for their return trip to Manila, the Ganas had to purchase new tickets at adjusted rates.
Upon returning to Manila, the Ganas filed a lawsuit against Air France alleging breach of contract and sought damages. The trial court dismissed the complaint, but the decision was overturned by the Court of Appeals, which awarded P90,000.00 as moral damages to the Ganas. Air France then appealed to the Supreme Court.
### Issues:
1. Whether the Ganas had a valid case for breach of contract of carriage against Air France.
2. Whether Air France’s refusal to honor the expired tickets and its demand for payment of adjusted fare rates constituted breach of contract or bad faith.
### Court’s Decision:
The Supreme Court reversed the decision of the Court of Appeals and dismissed the amended complaint filed by the Ganas. The Court found that:
– Air France was in compliance with IATA tariff rules, which dictated the validity period of tickets and the conditions for their extension.
– It was not Air France’s responsibility that the Ganas were uninformed of the expiry and revalidation rules; Teresita Manucdoc, acting on their behalf, was duly informed.
– Air France’s conduct did not constitute a breach of contract as the refusal to accept the expired tickets and the imposition of additional charges were in accordance with existing regulations.
– The predicament faced by the Ganas was due to their own decision to proceed with their journey despite knowing the tickets’ limitations.
### Doctrine:
This case reaffirms the doctrine that parties to a contract of carriage must abide by tariff rules and regulations, including those pertaining to ticket validity and re-issue requirements. Knowledge of these regulations by the agent is imputed to the principal.
### Class Notes:
– **Contract of Carriage:** A legal agreement between a carrier and a passenger, governed by tariff rules and regulations.
– **IATA Tariff Rules:** Internationally agreed upon regulations that define the validity, extension, and adjustment of air tickets.
– **Agency Principle:** Notice to the agent is notice to the principal, especially regarding contractual obligations and conditions.
### Historical Background:
This case highlights the complexities of international travel arrangements and the legal implications of the rules set by the International Air Transportation Association (IATA). It underscores the importance for passengers and their agents to be fully aware of the conditions tied to their travel documents to prevent disputes that may arise from misunderstandings or miscommunications about those conditions.
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