Case Digest (G.R. No. 119706)
Facts:
- On January 27, 1990, Gilda C. Mejia shipped a microwave oven from San Francisco, USA, to Manila, Philippines, via Philippine Airlines (PAL).
- Upon arrival, the microwave oven's front glass door was found broken, making it unserviceable.
- Mejia made both oral and written demands for reimbursement from PAL, which were ignored.
- Consequently, Mejia filed a lawsuit for damages on September 25, 1990.
- PAL argued the court lacked jurisdiction, that it acted in good faith, and that it had exercised due diligence in handling the cargo.
- The trial court ruled in favor of Mejia, awarding her P30,000 in actual damages, P10,000 in moral damages, P20,000 in exemplary damages, and P10,000 in attorney's fees.
- PAL's counterclaim was dismissed.
- The Court of Appeals affirmed the trial court's decision, prompting PAL to file a petition for review.
Issue:
- (Unlock)
Ruling:
- The air waybill is valid and binding, but its provisions should be scrutinized and interpreted strictly against PAL.
- PAL's liability is not limited to US$20 per kilogram due to the circumstances surrounding the advice given to Mejia by PAL's personnel.
- Mejia substantially complied with the requirement for the immediate filing of a f...(Unlock)
Ratio:
Validity of Air Waybill:
- Contracts of adhesion, like the air waybill, are not invalid per se.
- Such contracts must be closely scrutinized, especially in the presence of ambiguities.
- Contracts should be interpreted strictly against the drafter, in this case, PAL, to protect the weaker party.
Limitation of Liability:
- PAL's personnel advised Mejia against declaring the value of the microwave oven, estopping PAL from invoking the limited liability clause.
- PAL's acceptance of the cargo without requiring a declaration of value and advising against it assured Mejia that it was unnecessary.
- Therefore, PAL could not limit its liability to US$20 per kilogram.
Filing of Formal Claim:
- Mejia substantially complied with the requirement for the immediate filing of a formal claim.
- The delay in filing the formal claim was due to PAL's personnel, who mishandled the claim.
- Article 1186 of the Civil Code applies, deeming a...continue reading
Case Digest (G.R. No. 119706)
Facts:
On January 27, 1990, Gilda C. Mejia shipped a microwave oven from San Francisco, USA, to Manila, Philippines, via Philippine Airlines (PAL). Upon arrival, the microwave oven's front glass door was found broken, rendering it unserviceable. Mejia made both oral and written demands for reimbursement from PAL, which were ignored. Consequently, Mejia filed a lawsuit for damages on September 25, 1990. In its defense, PAL argued that the court lacked jurisdiction, that it acted in good faith, and that it had exercised due diligence in handling the cargo. The trial court ruled in favor of Mejia, awarding her P30,000 in actual damages, P10,000 in moral damages, P20,000 in exemplary damages, and P10,000 in attorney's fees. PAL's counterclaim was dismissed. The Court of Appeals affirmed the trial court's decision, leading PAL to file a petition for review.
Issue:
- Is the air waybill, being a contract of adhesion, valid and binding on the parties?
- Should PAL's liability be limited to US$20 per kilogram as stipulated in the air waybill?
- Did Mejia comply with the requirement for the immediate filing of a formal claim for damages?
- Is PAL liable for moral and exemplary damages, and attorney's fees?
Ruling:
- The air waybill is valid and binding, but its provisions should be scrutinized and interpreted strictly against PAL.
- PAL's liability is not limited to US$20 per kilogram due to the circumstances surrounding the advice ...