KOREAN AIRLINES CO., LTD., vs. COURT OF APPEALS and JUANITO C. LAPUZ.
- G.R. Number: G.R. No. 114061
- Promulgated: 1994-08-03
- Ponente: Cruz, J.
Doctrine
Findings of fact by the Court of Appeals are generally binding on the Supreme Court unless specific exceptions justify review.
Damages based on speculative future contract renewals (loss of anticipated earnings subject to employer's decision) should not be awarded as speculative.
Legal interest on monetary awards runs from the rendition of the trial court's decision rather than from the filing of the complaint.
Facts
Lapuz, an automotive electrician, was contracted for one-year employment in Jeddah, Saudi Arabia through Pan Pacific and was to leave on 8 November 1980 via Korean Airlines (KAL); he was initially wait-listed but obtained a seat when two confirmed passengers did not appear.
Lapuz checked in, passed customs and immigration, was cleared as Passenger No. 157 of KAL Flight No. KE 903, proceeded to board but was stopped on the stairs by a KAL officer, barred from boarding, and his ticket was canceled, preventing him from reporting for work in Saudi Arabia.
KAL and Lapuz filed separate motions for reconsideration after the Court of Appeals decision; both were denied and the petitions for review were consolidated due to identical parties and similar issues.
Issues
Whether the factual findings of the Court of Appeals are binding on this Court absent exceptional circumstances.
Whether the award of damages for loss of earnings from contract renewal is proper or speculative, and what date legal interest should commence to run on the damages.
Whether the trial court correctly dismissed KAL's counterclaim against Pan Pacific Overseas Recruiting Services, Inc.
Ruling
The Court affirmed that the factual findings of the Court of Appeals are generally binding on the Supreme Court absent recognized exceptions; here no exception appearing, the appellate factual conclusions are affirmed.
The Court modified the awards: actual/compensatory damages reduced to P60,000.00; moral and exemplary damages of P100,000.00 awarded; legal interest set at 6% per annum to run from the trial court's decision date (14 November 1990).
The Court sustained the trial court's dismissal of KAL's counterclaim against Pan Pacific, finding Pan Pacific's responsibility ended once KAL confirmed Lapuz as a passenger on Flight No. 903.
The appealed judgment is affirmed with modification to the commencement date for legal interest; parties to bear their own costs.
Keywords
G.R. No. 114061, G.R. No. 113842, breach of contract of carriage, actual/compensatory damages, attorney's fees, costs of suit, moral damages, exemplary damages, legal interest, wait-listed passenger, confirmed passenger, passenger manifest, contract to transport passengers, public duty, damages against the carrier, factual findings, petitions for review, abuse of discretion, contractual relation, lapuz