G.R. No. L-44936 - Philippine Airlines, Inc. vs. Court of Appeals

On April 4, 1972, private respondent Chua Min boarded Philippine Airlines’ Flight PR 301 from Hongkong to Manila.
He checked in four pieces of baggage, two of which allegedly contained cinematographic films.

Upon arrival in Manila, Chua Min could not locate two pieces of baggage containing the film rolls despite a diligent search.
The airline admitted the loss and offered to compensate based on an internal valuation, but Chua Min opted to file a suit seeking recovery for his estimated loss of P20,000.00.

The trial court, presided over by Hon. Francisco de la Rosa, rendered a judgment on December 10, 1974 against Philippine Airlines.
The judgment ordered the airline to pay the plaintiff the Philippine peso equivalent of U.S.$4,000.00 (calculated using the exchange rate of March 1972), with legal interest from the filing of the suit, payment of costs, and dismissal of the compulsory counterclaim.

Private respondent testified through Chua Min and presented four key documents to support the claim.
Philippine Airlines, as petitioner, failed to produce any witnesses and simply adopted private respondent’s exhibits, which included the film valuation documents.
Philippine Airlines contended that the contract of carriage was defined by the terms printed on the passenger ticket, which also contained stipulations on baggage allowance and referenced the liability limitations under the Warsaw Convention.

Petitioner argued that the passenger ticket (issued to Chua Min) and the baggage check were distinct items – the ticket governed carriage while the baggage check should detail the baggage and its weight.
In its motion for reconsideration, however, the airline later argued that the two documents were one, claiming that the baggage check was retained by the passenger and that it could not be produced in court.
The airline invoked provisions from the Warsaw Convention, particularly Article 22(2), limiting its liability for lost baggage, and relied on the free baggage allowance clause in the ticket.
Crucially, the trial court observed that petitioner did not introduce its own evidence to support the existence or validity of the baggage check, instead relying solely on private respondent’s exhibits.

A letter from Philippine Airlines dated August 28, 1972, acknowledged the loss and explicitly stated the limitation of liability based on the weight of the baggage as certified by the Property Irregularity Report (PIR) and the ticket details.
Testimony and documentary evidence emphasized that Chua Min, as the person who suffered the loss, had the standing to initiate the suit by virtue of being the de facto consignee, responsible for the films regardless of their ultimate ownership.

Whether Philippine Airlines, as the carrier, may invoke the limitation clause under Article 22(2) of the Warsaw Convention to cap its liability for the lost baggage.
Whether the conditions stipulated by the Convention – particularly the presentation and proper issuance of the baggage check as required by Article 4 – were satisfied.

Whether Chua Min, through his actions and testimony, qualifies as the real party-in-interest despite suggestions from his own statements at the trial.
Whether the admitted responsibility for the film rolls, including the acknowledgment contained in the airline’s correspondence, renders him entitled to compensation.

Whether the passenger ticket, which also contained baggage allowance and liability limitation clauses, could be equated with a baggage check.
Whether Philippine Airlines’ failure to produce an independent baggage check undermined its plea to limit its liability.