G.R. No. 100374-75 - Luna vs. Court of Appeals

Petitioners, Rufino Y. Luna, Rodolfo J. Alonso, and Porfirio Rodriguez, boarded Flight 020 of Northwest Airlines on 19 May 1989, bound for Seoul, South Korea, to attend a Rotary International Convention.
Each passenger checked in one piece of luggage at the time of boarding.

After boarding, the flight encountered engine trouble, compelling the passengers to disembark and transfer to a Korean Airlines plane scheduled to depart four hours later.
The airline assured that the baggage would be forwarded on the same flight, however, upon arrival in Seoul, none of the petitioners’ baggage was present as expected.
It was later discovered that the luggage had been taken to Seattle, U.S.A., rather than remaining at the destination.

Petitioners eventually retrieved their luggage four days later, after persistent efforts and repeated representations with Northwest Airlines personnel at the Seoul airport.
The delay caused significant disruption to their travel plans, notably affecting their ability to attend the scheduled convention.

Petitioners Luna and Alonso sent their written claim on 6 June 1989, while petitioner Rodriguez filed his claim on 13 June 1989.
Despite the claims, Northwest Airlines disclaimed liability in a letter dated 21 June 1989, asserting that it had exerted its best efforts to ensure timely handling of both passengers and baggage.
Subsequent to the claims, Luna and Alonso filed a complaint for breach of contract with damages before the RTC of Pasig (Civil Case No. 58390), and Rodriguez filed a separate complaint before the RTC of Valenzuela (Civil Case No. 3194-V-89).

The trial courts dismissed both complaints due to the alleged failure of petitioners to file their claims within the period prescribed by the Warsaw Convention.
Petitioners sought relief through a petition for certiorari before the Court of Appeals and directly before the Supreme Court, contesting the dismissal and arguing that the Convention’s provisions should not preclude claims governed by the Civil Code and other laws.
The Court of Appeals, relying on the Warsaw Convention’s reglementary period and the notion that certiorari is not a substitute for a lost appeal, dismissed the petitions; both motions for reconsideration were subsequently denied.

Whether the application of the Warsaw Convention excludes the operation of the provisions of the Civil Code and other pertinent statutes in cases of delayed baggage delivery.

Whether the trial and appellate courts erred in limiting the scope of the petitions solely to compliance with the filing requirements of the Warsaw Convention, thereby dismissing the claims on technical grounds.

Whether certiorari can serve as a substitute for a lost appeal in instances where a rigid application of procedural rules results in a manifest failure or miscarriage of justice.

Whether the failure to file a claim within the 21-day reglementary period prescribed by the Warsaw Convention should bar the recovery of damages when other legal provisions might impose a different period or procedure for filing a claim.