Augusto Benedicto Santos Iii v. Northwest Orient Airlines

Summary

A minor Philippine resident sued Northwest Orient Airlines in Philippine courts for damages after his confirmed airline reservation was cancelled, forcing him to be wait-listed. The Supreme Court denied the petition, ruling that under the Warsaw Convention Article 28(1), damage actions against international air carriers can only be filed in four specific venues: carrier's domicile, principal place of business, place where contract was made, or place of destination. The Court held Philippines qualified under none of these categories since NOA's domicile and principal business were in the U.S., the ticket was purchased in San Francisco, and the ultimate destination was San Francisco (not Manila, which was merely an agreed stopping place). The Court rejected constitutional challenges to the treaty, clarified that Article 28(1) is jurisdictional rather than merely procedural, and ruled the petitioner must pursue his case in U.S. courts. The decision demonstrates the binding nature of international treaties and limitations they may impose on access to domestic courts.