G.R. No. 199403 - People vs. Climaco

Dr. Felipa Pablo, an associate professor at the University of the Philippines and research grantee of the Philippine Atomic Energy Agency, was invited to a United Nations meeting in Ispra, Italy, organized by the Joint FAO-IAEA Division of Atomic Energy in Food and Agriculture.
Her specialized knowledge in "foreign substances in food and the agriculture environment" led to her invitation to present a paper titled "The Fate of Radioactive Fusion Products Contaminating Vegetable Crops." She was scheduled as the second speaker on the first day of the meeting.

Dr. Pablo booked her travel with ALITALIA airline to attend the conference and arrived in Milan the day before the meeting.
Upon arrival, ALITALIA personnel informed her that her two suitcases—one containing clothes and personal effects, and the other containing scientific papers, slides, and research materials—were delayed due to being on a subsequent flight from Rome to Milan.
Attempts to locate the luggage on other flights failed, prompting Dr. Pablo to go personally to Rome to search for her baggage.
She inquired at airports in Rome and completed ALITALIA’s prescribed forms, but the luggage remained missing.

Unable to retrieve her baggage in time, Dr. Pablo did not attend the conference and returned to Manila.
ALITALIA later located and forwarded her suitcases to Ispra the day after her scheduled presentation; by then, she had already left for Manila.
Actual delivery of the luggage to Dr. Pablo occurred eleven months later and four months after the filing of her lawsuit against ALITALIA.

Dr. Pablo filed suit against ALITALIA on June 7, 1973, seeking damages for the breach of contract caused by the delayed luggage and missed conference participation.
The Regional Trial Court ruled in favor of Dr. Pablo, awarding:

ALITALIA appealed to the Intermediate Appellate Court (IAC), which affirmed the decision but increased the nominal damages to P40,000. The IAC justified this increase due to inflation and the frustration, embarrassment, and humiliation suffered by Dr. Pablo.
ALITALIA elevated the case to the Supreme Court via certiorari, raising similar defenses and contending the IAC erred in not passing on all assigned errors or clearly stating the basis of its decision.

Whether or not the Warsaw Convention limits ALITALIA’s liability in respect to the delay of Dr. Pablo’s baggage and her consequent damages.
Whether the award of nominal damages and attorney’s fees to Dr. Pablo was justified under the circumstances and the law.
Whether the Intermediate Appellate Court erred in refusing to pass on all assigned errors and failing to state the facts and law supporting its decision adequately.