Petitioner
Philippine Airlines
Respondent
Hon. Adriano Savillo
Citation
G.R. No. 149547
Court
Supreme Court
Division
Third Division
Ponente
Chico-Nazario, J.
Decided
July 4, 2008

Summary

The Supreme Court ruled that claims for moral damages arising from emotional distress caused by airline negligence in international air travel fall under Civil Code tort provisions rather than the Warsaw Convention's exclusive coverage. PAL passenger Griño was stranded in Singapore when Singapore Airlines refused to honor his Jakarta-bound ticket due to PAL's failure to provide proper endorsement. The Court distinguished between damages for transportation delays (covered by Warsaw Convention with two-year prescription) and damages for emotional harm from unjust denial of boarding (covered by Civil Code with four-year prescription). Since Griño's complaint was filed within four years of his demand letter, the case was not time-barred. This decision clarifies that the Warsaw Convention does not exclusively regulate all aspects of the passenger-carrier relationship in international flights.

Intellegal Wiki · Key Holding

Denied PAL's petition; claims for emotional harm from an unjust denial of boarding fall under Civil Code tort, prescribing in four years under Article 1146, not the Warsaw Convention's two-year limit.

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By the Intellegal Editorial Board · July 4, 2008

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