G.R. No. 177927 - Quizon vs. Commission on Elections

On April 17, 1985, plaintiff Isidro Co, accompanied by his wife and son, arrived at Manila International Airport via Philippine Airlines’ Flight No. 107 from San Francisco, California.
Upon arriving at the baggage retrieval area, plaintiff claimed his nine checked-in pieces of luggage using the corresponding claim checks.
Plaintiff successfully located eight pieces of luggage but failed to locate the ninth piece, identified by claim check number 729113.

Plaintiff immediately notified the defendant airline through its employee, Willy Guevarra, who was in charge of the PAL claim counter.
Willy Guevarra prepared and signed a Property Irregularity Report, a printed document acknowledging the missing luggage, and requested the plaintiff to sign the report as well.
As part of standard procedure, the officer collected all nine claim checks, including the one corresponding to the missing item.

The lost item was a Samsonite suitcase, approximately 62 inches in length, valued at about US$200.00.
The suitcase contained various personal effects purchased by the plaintiff and his wife during their stay in the United States.
Additional items, brought into the suitcase as gifts from friends abroad, were estimated to be worth between US$500.00 and US$600.00, while invoices showed the value of personal effects at US$1,243.01.

After repeated personal visits and inquiries at the defendant’s office, the plaintiff’s dissatisfaction led him to secure legal counsel.
On April 15, 1985, plaintiff’s lawyer sent a demand letter via Rebecca V. Santos, manager of the Central Baggage Services, urging prompt resolution.
On April 17, 1985, Rebecca Santos replied acknowledging that the airline had been unable to locate the missing baggage and extended apologies for the inconvenience.
Despite the acknowledgment, the airline failed to locate the luggage or to render any payment compensating the loss.

On May 3, 1985, noticing the airline's inaction, plaintiff filed a complaint seeking damages.
The Regional Trial Court of Pasay City found the defendant liable and rendered a judgment on June 3, 1986, awarding:

The airline contended that its retrieval baggage report was a fabrication.
It argued that the limits under the Warsaw Convention, which restrict liability for checked-in baggage to US$20.00 based on weight, should have been applied.
The petitioner also challenged the award of actual damages, exemplary damages, and attorney’s fees, asserting that these amounts were not substantiated under the applicable law.

Whether the airline’s retrieval report, which played a central role in contesting the claim, was a fabrication.
Whether the burden shifted to the airline to produce corroborative evidence proving the veracity of its report.

Whether the limits of liability imposed by the Warsaw Convention, particularly the US$20.00 cap based on weight, should be applied in this case.
Whether the plaintiff’s failure to declare a higher value or pay additional charges before the flight invokes such limitation.

Whether the trial court and appellate courts erred in awarding actual and exemplary damages, along with attorney’s fees, considering the factual findings.
Whether these awards are justified based on the evidence of negligence and bad faith on the part of the airline.

Whether the issues pertaining to the factual determinations by the lower courts are reviewable on a petition for review, given that they involve matters not clearly set forth as questions of law.