Case Digest (G.R. No. 101538) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Santos v. Northwest Orient Airlines, the petitioner, minor Augusto Benedicto Santos III, through his father and legal guardian Augusto Benedicto Santos, purchased on October 21, 1986, a round-trip ticket from San Francisco to Manila via Tokyo (with no specified return date) from private respondent Northwest Orient Airlines (NOA), a Minnesota-incorporated carrier licensed to maintain a branch office in the Philippines. On December 19, 1986, despite prior confirmation, the petitioner discovered at Tokyo that he lacked a confirmed seat to Manila and was wait-listed. On March 12, 1987, he filed a damage suit in the Regional Trial Court (RTC) of Makati. On April 13, NOA moved to dismiss for lack of jurisdiction, invoking Article 28(1) of the Warsaw Convention, which limits actions for damages to four designated fora: the carrier’s domicile, principal place of business, place of contract, or place of destination. On February 1, 1988, the RTC granted the motion; the Court of Appeals Case Digest (G.R. No. 101538) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioner: Augusto Benedicto Santos III, a minor and Philippine resident, represented by his father and legal guardian.
- Respondent: Northwest Orient Airlines (NOA), a Minnesota-based foreign corporation licensed to do business and maintain a branch office in the Philippines.
- Transaction and Incident
- On October 21, 1986, petitioner purchased in San Francisco a round-trip ticket from NOA for travel San Francisco→Tokyo→Manila (departure from Tokyo set for December 20, 1986) and return (date unspecified).
- On December 19, 1986, at San Francisco airport check-in for the Tokyo→Manila segment, petitioner learned he had no confirmed reservation for that leg and was placed on a waiting list.
- Procedural History
- March 12, 1987: Petitioner filed suit for damages in the Regional Trial Court (RTC) of Makati.
- April 13, 1987: NOA moved to dismiss for lack of jurisdiction under Article 28(1) of the Warsaw Convention, arguing the Philippines was neither its domicile nor principal place of business, the contract was not made there, and Manila was not petitioner’s ultimate destination.
- February 1, 1988: RTC granted the motion and dismissed the case.
- On appeal, the Court of Appeals affirmed the RTC decision; a motion for reconsideration was denied on June 26, 1991.
- Petitioner elevated the case to the Supreme Court via petition for review on certiorari.
Issues:
- Constitutionality of Article 28(1) of the Warsaw Convention
- Does Article 28(1) violate due process and equal protection by arbitrarily classifying permissible fora?
- Is the Convention inapplicable under the doctrine of rebus sic stantibus due to changed industry conditions?
- Does application of Article 28(1) deny petitioner access to Philippine courts?
- Jurisdiction under Article 28(1)
- Is Article 28(1) a waivable rule of venue rather than a jurisdictional bar?
- Can Manila be deemed the place of destination under the Convention?
- Does NOA’s Philippine branch constitute its domicile?
- Do allegations of tort or willful misconduct remove the case from Warsaw coverage?
- Protection of Minors
- Does Civil Code Article 24 permit Philippine courts to assume jurisdiction on grounds of petitioner’s minority and vulnerability?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)