- Petitioner
- Franklin G. Gacal
- Respondent
- Philippine Air Lines
- Citation
- G.R. No. 55300
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Paras, J.
- Decided
- March 15, 1990
Summary
Passengers Franklin and Corazon Gacal sued Philippine Air Lines for damages after being injured during a 1976 hijacking incident where MNLF members took control of their Davao-Manila flight. The hijacking ended in a military siege at Zamboanga Airport, resulting in casualties and passenger injuries. The trial court dismissed their damage claims, ruling the hijacking was force majeure. The Supreme Court affirmed, establishing important precedent that during martial law, when military authorities had exclusive control over airport security, airlines could not be held liable for hijacking incidents as they constituted unforeseeable and unavoidable force majeure. The decision clarified the four essential elements of caso fortuito under Civil Code Article 1174 and reinforced that common carriers' extraordinary diligence duty is limited by circumstances beyond their control, particularly when government agencies assume exclusive jurisdiction over security functions.