Each of these is a refusal this regime lets a counterparty attempt, paired with the answer to it. Reading them before you write is worth more than any amount of polish on the letter itself.
The airline applies the 2012 thresholds
high likelihoodThe carrier says care becomes due at three hours and the cancellation election at six, which is what the 2012 Joint Administrative Order provided.
What answers it
Economic Regulation No. 9 As Amended, adopted 30 January 2024, moved those tiers to two and four hours. Cite the amended regulation by name and date. The CAB's own summary page carries the amended figures.
CAB Economic Regulation No. 9, As Amended, § 13.1 (terminal delay of two hours or more) — § 13.1 (terminal delay of two hours or more)
Here is PHP 5,000, that is the rate
high likelihoodFor denied boarding the carrier pays the peso figure and treats it as the tariff.
What answers it
Section 11.1(c)(i) pays the HIGHER of the full fare including taxes, surcharges and optional service items, or the peso figure. On any fare above the floor, the fare governs — and "optional service items" means seat selection, bags and meals count toward the base. It is a floor, not a rate.
CAB Economic Regulation No. 9, As Amended, § 11.1(c)(i) (denied boarding compensation) — § 11.1(c)(i) (denied boarding compensation)
A voucher rather than cash
high likelihoodThe carrier issues a travel voucher and treats the obligation as discharged.
What answers it
A voucher must be convertible to cash within fifteen days. Ask for the conversion in writing and cite the requirement. Separately, § 13.2 gives the carrier the choice of cash or voucher for the delay compensation specifically — but not the right to make a voucher permanent.
CAB Economic Regulation No. 9, As Amended, § 13.2 (terminal delay of four hours or more attributable to the carrier) — § 13.2 (terminal delay of four hours or more attributable to the carrier)
Overbooking is standard practice
medium likelihoodThe carrier presents the offload as an ordinary consequence of a commercial practice everyone uses.
What answers it
Section 11.1(f) caps overbooking at 10% of seat capacity and provides that a carrier exceeding it is acting in bad faith. That is a finding with consequences beyond your ticket. Ask the carrier how many passengers were offloaded and what the aircraft's seat capacity was, and put the answer — or the refusal — in your CAB complaint.
CAB Economic Regulation No. 9, As Amended, § 11.1(f) (overbooking limit) — § 11.1(f) (overbooking limit)