Edna Diago Lhuillier v. British Airways

Summary

Filipino passenger Edna Lhuillier sued British Airways for damages arising from alleged mistreatment by flight attendants during flight from London to Rome, claiming violations of Civil Code provisions on human relations and quasi-delict. British Airways moved to dismiss for lack of jurisdiction under Warsaw Convention Article 28(1). RTC Makati granted dismissal, ruling Philippine courts lacked jurisdiction since case involved international carriage between Warsaw Convention signatories UK and Italy, and Philippines was neither carrier's domicile, principal business place, contract formation place, nor destination. Supreme Court affirmed, holding Warsaw Convention has force of law as treaty commitment, tortious conduct claims don't exempt case from Convention's exclusive jurisdictional provisions, and respondent's special appearance didn't constitute voluntary submission to jurisdiction. Case demonstrates supremacy of international treaty obligations over domestic jurisdiction preferences.