Case Digest (G.R. No. 55300) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 55300, decided March 15, 1990 under the 1987 Philippine Constitution, petitioners Franklin G. Gacal and his wife Corazon M. Gacal, together with co-plaintiffs Bonifacio S. Anislag and his wife Mansueta L. Anislag, and the late Elma de Guzman, boarded a Philippine Airlines, Inc. (PAL) BAC 1-11 aircraft (RP-C1161) at Davao Airport on May 21, 1976, bound for Manila. Ten minutes after takeoff, six members of the Moro National Liberation Front, three armed with grenades and three with pistols, seized control of the plane and ordered the pilot to fly to Libya. Upon learning of fuel limitations, the hijackers diverted to Zamboanga Airport, where they demanded a DC-aircraft, ransom, and hostages, threatening execution if their terms were unmet. The hostages were deprived of adequate food and water until May 23, after which a military assault ensued. The clash left ten passengers and three hijackers dead, three hijackers captured, and survivors injured: Mrs. Corazon M. Gacal Case Digest (G.R. No. 55300) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- Petitioners Franklin G. Gacal and Corazon M. Gacal (assisted by her husband) filed Civil Case No. 1701 for damages against Philippine Air Lines, Inc. (PAL) before the Court of First Instance (CFI) of South Cotabato, Branch I.
- Three consolidated cases for damages (Nos. 1701, 1773, 1797) were dismissed by the CFI on August 26, 1980, as being caused by force majeure.
- Hijacking Incident
- On May 21, 1976, petitioners and other passengers boarded PAL BAC 1-11 at Davao Airport for Manila. Six armed hijackers (members of the MNLF) were undiscovered co-passengers.
- Ten minutes after takeoff, the hijackers announced the seizure, ordered flight to Libya, then to Sabah, and ultimately to land at Zamboanga for refueling.
- Standoff and Rescue
- Upon landing at Zamboanga (3:00 p.m.), the hijackers made political and ransom demands, threatened to blow up the plane, and denied passengers food and water until May 23.
- A military assault ensued when relatives of hijackers left the plane. The rescue left ten passengers and three hijackers dead on the spot; three hijackers were captured.
- Injuries, Damages, and Procedural History
- Mrs. Corazon Gacal suffered injuries from bullets and grenade blasts, incurring P245.60 in hospital expenses. Elma de Guzman died; Mrs. Mansueta Anislag suffered an elbow fracture costing P4,500.
- Petitioners appealed on pure questions of law to the Supreme Court via petition for review on certiorari (filed October 20, 1980). Both parties filed briefs; petitioners did not file a reply brief.
Issues:
- Whether the hijacking of PAL Flight RP-C1161 during Martial Law constituted a fortuitous event or force majeure that exempts PAL from liability as a common carrier.
- Whether PAL failed in its duty to exercise extraordinary diligence under Article 1733 of the Civil Code by not detecting the hijackers carrying weapons.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)