Sabena Belgian World Airlines v. Hon. Court of Appeals

Summary

This case involves airline liability for lost luggage beyond Warsaw Convention limitations. Ma. Paula San Agustin's luggage containing $4,265 worth of valuables was lost twice by Sabena Belgian World Airlines during her international travel. The Supreme Court affirmed lower courts' awards of full actual damages plus moral and exemplary damages, ruling that the airline's gross negligence (losing luggage twice) constituted willful misconduct equivalent to fraud. This gross negligence forecloses the airline's right to invoke Warsaw Convention liability limitations. The Court applied Civil Code provisions requiring common carriers to observe extraordinary diligence, establishing that when such diligence is breached through gross negligence, carriers become liable for all reasonably attributable damages. The decision reinforces that international aviation conventions do not provide absolute liability limits when carriers engage in willful misconduct or gross negligence, and domestic law governs recovery in such circumstances.