G.R. No. 149547 ; July 4, 2008
PHILIPPINE AIRLINES, INC., petitioner, vs. HON. ADRIANO SAVILLO, Presiding Judge of RTC Branch 30, Iloilo City, and SIMPLICIO GRIÑO, respondents.

FACTS

Private respondent Simplicio Griño purchased a PAL ticket for a Manila-Singapore-Jakarta-Singapore-Manila itinerary for a golf tournament. Upon arrival in Singapore on October 3, 1993, Singapore Airlines refused to honor the connecting ticket to Jakarta due to lack of endorsement by PAL, whose airport office was closed. Stranded, Griño and his companions were forced to purchase new tickets on a different airline, arriving in Jakarta very late, missing their arranged transport, and causing him distress and illness that prevented his tournament participation. After his return, his demand letters to PAL and Singapore Airlines were unheeded.
On August 15, 1997, Griño filed a Complaint for Damages against PAL before the RTC of Iloilo. PAL moved to dismiss the complaint on the ground of prescription, arguing that the claim is governed by the Warsaw Convention, which prescribes in two years from the date of arrival. The RTC denied the motion, ruling that the Civil Code, not the Warsaw Convention, applied. The Court of Appeals affirmed the RTC’s order.

ISSUE

Whether the Regional Trial Court correctly denied PAL’s Motion to Dismiss on the ground that the action had not prescribed.

RULING

Yes, the RTC correctly denied the Motion to Dismiss. The Supreme Court held that the Warsaw Convention’s two-year prescriptive period does not apply to all of Griño’s claims. The Convention governs claims arising from the “international transportation of persons,” which primarily refers to liability for accidents, delay, or loss in the actual carriage. Griño’s complaint, however, detailed injuries stemming not from the physical carriage itself but from PAL’s alleged failure to properly endorse the tickets and ensure his confirmed passage, resulting in his being stranded. This gave rise to causes of action potentially based on breach of contract, negligence, or even tort under Articles 19, 21, and 2176 of the Civil Code.
The Court emphasized that the Warsaw Convention does not provide the exclusive remedy for all possible claims between a passenger and an airline. Claims that are independent of the actual performance of the contract of carriage, such as those arising from acts or omissions that occur before or after the flight or are ancillary to it, may be governed by domestic law. Since Griño’s claims for moral damages due to humiliation, anxiety, and illness could be rooted in these separate legal grounds under the Civil Code, which has longer prescriptive periods, the trial court was correct in not dismissing the case outright. The determination of the applicable law and prescription period requires a full trial on the merits.