Philippine Airlines v.

Ramos
G.R. No. 92740
March 23, 1992

MEDIALDEA, J.:

FACTS:
Jamie Ramos, Nilda Ramos, Erlinda Illano, Milagros Illano, Daniel Illano and felipa Javalera
(Plaintiffs) were officers of the Negros Telephone Company who held confirmed tickets for PAL flight
Naga to Manila. The plane should depart for Manila at 4:25. Plaintiffs complained that they were
not allowed to board their PAL (Philippines Air Lines) flight, despite the fact that they went to the
check-in counter one hour before departure. They alleged that when they arrived there no one was
at the counter. They testified that the PAL clerk arrived 30 minutes before departure. PAL however,
presented as evidence the plaintiffs’ tickets with notation “late 4:04” and the passenger manifest
which showed that two other passengers who arrived earlier than plaintiffs, were not
accommodated. PAL also presented their daily station report that there were personnel who were
stationed on the counter to assist all passengers including late ones by informing them of the results
of their tardiness.

RTC ruled in favor of the plaintiffs for breach of contract by PAL

CA affirmed the decision in toto.

ISSUE:
Whether the documents presented by PAL admissible? Which should prevail the oral
testimony of plaintiffs or the documentary evidence presented by PAL?

HELD:
Yes. The documentary evidence presented by PAL to corroborate the testimonies of its
witnesses are entries made in the regular course of business which plaintiffs failed to overcome with
substantial and convincing evidence other than their testimonies. Consequently they carry more
weight and credit. A writing or document made contemporaneously with a transaction which are
evidence of facts pertinent to an issue, when admitted as proof of those facts, is ordinarily regarded
as more reliable proof and of greater probative force than the oral testimony of a witness as to such
fact based upon memory and recollection. Spoken words could be notoriously unreliable as against
a written document that speaks a uniform language.