9/12/24, 6:40 PM Case Digest: G.R. No. 123560 - Spouses Yu vs. Pan American World Airways, Inc.
Title
Spouses Yu vs. Pan American World Airways, Inc.
Case Decision Date
G.R. No. 123560 Mar 27, 2000
Spouses Yu purchased plane tickets from an independent travel agent who
misrepresented the confirmation of tickets, leading to their inability to board the
flight, and while the airline was not held liable, the agent could be held liable for
misrepresentation.
Case Digest (G.R. No. 123560)
Comprehensive
Facts:
The case involves Spouses Yu Eng Cho and Francisco Tao Yu (petitioners) who
purchased plane tickets from Claudia Tagunicar, an independent travel agent who
claimed to be an agent of Tourist World Services, Inc. (TWSI). The tickets were for a trip
from Manila to Hong Kong, Tokyo, and San Francisco. The Tokyo-San Francisco leg was
initially on "RQ" (request) status. Tagunicar later confirmed this segment after contacting
Julieta Canilao of TWSI and affixed confirmation stickers on the tickets. Upon arrival in
Tokyo, the petitioners were informed by Pan American World Airways, Inc. (Pan Am)
that their names were not on the passenger manifest. Consequently, they had to reroute
to Taiwan and eventually return to Manila due to unavailable flights. The petitioners filed
a complaint for damages against Pan Am, TWSI, Canilao, and Tagunicar. The Regional
Trial Court of Manila held all respondents, except Canilao, jointly and severally liable for
actual, moral, and exemplary damages. On appeal, the Court of Appeals reversed the
decision, absolving Pan Am and TWSI of liability and holding Tagunicar solely liable for
moral and exemplary damages and attorney's fees. The petitioners then sought a review
of this decision by the Supreme Court.
Issue:
1. Whether the Court of Appeals erred in finding that the petitioners' ticket
reservations were not confirmed.
2. Whether there was an agency relationship among Pan Am, TWSI, and Tagunicar,
making Pan Am liable for the actions of Tagunicar.
Ruling:
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9/12/24, 6:40 PM Case Digest: G.R. No. 123560 - Spouses Yu vs. Pan American World Airways, Inc.
1. The Supreme Court affirmed the decision of the Court of Appeals, holding that the
petitioners' ticket reservations were not confirmed.
2. The Supreme Court also affirmed that there was no agency relationship among Pan
Am, TWSI, and Tagunicar, thus absolving Pan Am of liability.
Ratio:
The Supreme Court found that the trial court's decision lacked a clear and distinct
statement of the factual and legal bases for holding the respondents jointly and severally
liable, as required by Section 14 of Article VIII of the 1987 Philippine Constitution. The
Court emphasized that affidavits are generally inferior to testimonial declarations given
in court. The Court also noted that the elements of an agency relationship were not
established, as there was no sufficient evidence to prove that Tagunicar was an
authorized agent of TWSI or Pan Am. The Court highlighted that the validation stickers
used by Tagunicar were unauthorized and that the petitioners' names were not on the
passenger manifest, indicating that their tickets were not confirmed. The Court also
pointed out that the petitioners were aware of the risk of not being accommodated on the
Tokyo-San Francisco flight, as evidenced by their repeated attempts to confirm their
tickets. Consequently, the Court held that Pan Am could not be held liable for damages,
and the liability for misrepresentation rested solely with Tagunicar, albeit mitigated by
the petitioners' awareness of the risk.
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