Nicholas Y. Cervantes v. Court of Appeals

Summary

Nicholas Cervantes sued PAL for damages after being denied boarding on an expired ticket despite prior flight confirmation by PAL agents. The Supreme Court affirmed the dismissal, ruling that the ticket's one-year validity period clearly expired on March 27, 1990, four days after Cervantes' departure. The Court held that PAL agents lacked authority to extend ticket validity through mere confirmation, and Cervantes knew from PAL's legal department that written extension requests were required. Under Civil Code Article 1898, unauthorized agent acts don't bind the principal when the third party knows of the authority limitations. The Court found no bad faith by PAL warranting damages, only simple negligence. The defense of lack of authority wasn't waived since the issue was litigated during trial with implied consent. This case establishes that airline ticket terms must be strictly interpreted and agent confirmations cannot override clear contractual limitations without proper authority.