Case Digest (G.R. No. 95536) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 95536, decided March 23, 1992 under the 1987 Constitution, petitioners Aniceto G. Saludo, Jr., Maria Salvacion Saludo, Leopoldo G. Saludo and Saturnino G. Saludo sought damages against Trans World Airlines, Inc. (TWA) and Philippine Airlines, Inc. (PAL) for the one‐day delay and mistaken shipment of their mother Crispina Galdo Saludo’s remains from Chicago to Cebu via San Francisco and Manila. On October 23, 1976, Crispina died in Chicago; Pomierski & Son Funeral Home embalmed her, obtained a disposition permit, and sealed her casket under Vice Consul Bienvenido Llaneta on October 26. The funeral home delivered the hermetically sealed casket to Continental Mortuary Air Services (CMAS), which arranged air transport and, through Air Care International as agent, secured PAL Airway Bill No. 079-01180454 booking the remains on TWA Flight 131 (Chicago–San Francisco, October 27) and PAL Flights 107 (San Francisco–Manila, October 27) and 149 (Manila–Cebu, October 29). Petiti Case Digest (G.R. No. 95536) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Death and Preparation of Remains
- October 23, 1976: Crispina Galdo Saludo dies in Chicago; Pomierski & Son Funeral Home embalm and prepare remains; obtain disposition permit; Philippine Vice Consul seals hermetic casket.
- Pomierski delivers sealed casket to Continental Mortuary Air Services (CMAS) for air‐freight arrangements.
- Booking and Mismatching of Shipment
- CMAS books shipment via Air Care International: requested routing Chicago–San Francisco (TWA Flight 131, Oct. 27), San Francisco–Manila (PAL Flight 107, Oct. 27), Manila–Cebu (PAL Flight 149, Oct. 29); PAL issues Airway Bill No. 079-01180454.
- October 27, 1976: TWA boards a corpse on Flight 603 (10 hours earlier)—due to CMAS switch, the wrong casket is loaded; TWA transfers it to PAL at 2:00 PM; CMAS withdraws it at 6:05 PM.
- October 28, 1976, 7:45 PM: Correct casket arrives via American Airlines; PAL loads remains on evening Flight 107 to Manila, arriving October 30.
- Litigation and Procedural History
- December 15, 1976 and June 10, 1977: Petitioners demand explanation and threaten suit against TWA and PAL for delay, disrespect.
- Petitioners file damage suit in CFI Leyte Branch III (Civil Case No. R-2101) seeking actual (₱50,000), moral (₱1,000,000), exemplary damages, attorney’s fees, costs.
- Trial court dismisses for lack of evidence; Court of Appeals affirms in CA-G.R. CV No. 20951; SC grant of certiorari limited to questions of law.
Issues:
- Did TWA or PAL fail to exercise the extraordinary diligence required, causing the misdelivery and delay of the remains?
- Does the one-day delay constitute a contractual breach entitling petitioners to damages?
- Are petitioners entitled to damages for alleged humiliating, arrogant or indifferent treatment by airline personnel?
- Should petitioners recover actual, moral or exemplary damages, attorney’s fees and litigation expenses?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)