Norberto Quisumbing, Sr. v. Court of Appeals

Summary

Passengers Quisumbing and Loeffler sued Philippine Air Lines for losses suffered during an armed robbery on a 1968 flight from Mactan to Manila, claiming breach of contract of carriage and failure to exercise extraordinary diligence under Civil Code Articles 1754, 1998, 2000-2001. Four armed robbers led by notorious criminal 'Zaldy' held up passengers after an NBI agent on board identified the suspect and attempted to alert authorities. The trial court, Court of Appeals, and Supreme Court all ruled in favor of PAL, finding that the armed robbery constituted force majeure for which the airline was not liable. The courts determined PAL exercised due diligence, complied with applicable regulations, and that passengers failed to notify the airline of valuable items as required by law. The Supreme Court affirmed that hindsight criticisms of PAL's security measures did not constitute negligence sufficient to overcome the force majeure defense.