Purita S. Mapa v. Court of Appeals

Summary

The Supreme Court reversed lower courts' dismissal of a damages suit against Trans-World Airlines for lost luggage. Petitioners Purita and Carmina Mapa lost four pieces of baggage during domestic US travel on TWA flights from New York to Boston in August 1990. The trial court and Court of Appeals dismissed the case, ruling Philippine courts lacked jurisdiction under Article 28(1) of the Warsaw Convention, which limits venue for international air transportation disputes. The Supreme Court disagreed, finding that the TWA tickets covered only domestic US travel and were not part of 'international transportation' under the Convention definition. The Court held that without clear evidence the parties regarded the separate Manila-Los Angeles (PAL) and domestic US (TWA) flights as a single undivided carriage, the Warsaw Convention's jurisdictional limitations did not apply. This decision clarified the scope of 'international transportation' under the Warsaw Convention and preserved Philippine courts' jurisdiction over certain airline liability cases.