G.R. No. 122191 October 8, 1998
SAUDI ARABIAN AIRLINES, petitioner, vs. COURT OF APPEALS, MILAGROS P. MORADA and HON. RODOLFO A. ORTIZ, in his capacity as Presiding Judge of Branch 89, Regional Trial Court of Quezon City, respondents.

FACTS

Private respondent Milagros P. Morada was hired by petitioner Saudi Arabian Airlines (SAUDIA) as a Flight Attendant based in Jeddah, Saudi Arabia. On April 27, 1990, during a lay-over in Jakarta, Indonesia, Morada was allegedly the victim of an attempted rape by a fellow crew member, Thamer Al-Gazzawi, with another crew member, Allah Al-Gazzawi, as an accomplice. Both were arrested by Indonesian police. Upon her return to Jeddah, SAUDIA officials interrogated her and requested her to return to Jakarta to help secure the release of the detained crew members, which she refused. The crew members were later deported and reinstated by SAUDIA. Morada was transferred to Manila in September 1990.
In January 1992, Morada was summoned to Jeddah, where SAUDIA’s Chief Legal Officer brought her to a police station. Her passport was taken, and she was pressured to drop the case against the crew members. In June 1993, she was again brought to Jeddah and to a Saudi court, where she was asked to sign documents in Arabic. On June 28, 1993, she was interrogated by a Saudi judge about the Jakarta incident. On July 3, 1993, the Saudi court rendered a decision sentencing her to five months imprisonment and 286 lashes for adultery, going to a disco, and socializing with male crew, in violation of Islamic laws. SAUDIA denied her assistance. The case against her was later dismissed by the Prince of Makkah, and she was allowed to leave Saudi Arabia. Shortly before her return to Manila, SAUDIA terminated her employment without informing her of the cause.
On November 23, 1993, Morada filed a Complaint for damages against SAUDIA and its country manager. She later filed an Amended Complaint dropping the manager as a defendant. SAUDIA filed motions to dismiss, arguing, among other grounds, that the trial court had no jurisdiction as the proper law applicable was the law of Saudi Arabia. The trial court denied the motions. SAUDIA filed a Petition for Certiorari with the Court of Appeals, which was denied. SAUDIA then elevated the case to the Supreme Court via a petition for review.

ISSUE

Whether the Regional Trial Court of Quezon City has jurisdiction to hear and try the complaint for damages based on Article 21 of the Civil Code, or whether the case involves a conflicts problem requiring the application of Saudi Arabian law.

RULING

The Supreme Court ruled that the Regional Trial Court has jurisdiction. The Court held that while the case involves a foreign element (the events occurred in Jakarta and Jeddah, and the employer is a foreign corporation), it is not a true conflicts problem. The Amended Complaint is anchored on Article 21 of the Civil Code, which is a valid cause of action. Jurisdiction over the subject matter is conferred by law and is determined by the allegations in the complaint. The complaint alleges that SAUDIA’s acts of bad faith, which led to Morada’s wrongful conviction and termination, occurred in the Philippines when it summoned her from Manila to Jeddah under false pretenses. The Court applied the “state of the most significant relationship” rule in conflicts law and found that the Philippines has the most significant contacts to the case: Morada is a Filipino citizen, she was recruited in the Philippines, her contract was processed through the POEA, and the actionable acts of SAUDIA (the summons from Manila) occurred in the Philippines. Therefore, Philippine law applies. The trial court correctly assumed jurisdiction. The petition was denied.