Case Digest (G.R. No. 122191)
Facts:
On January 21, 1988, Saudi Arabian Airlines (“SAUDIA”) employed Milagros P. Morada as a flight attendant based in Jeddah, Saudi Arabia. On April 27, 1990, while on lay-over in Jakarta, Indonesia, a Saudi national crew member attempted to rape Morada; security personnel intervened and Indonesian police arrested the assailant and an accomplice. Upon her return to Jeddah, SAUDIA officials interrogated her and sought her assistance to secure the release of the detained crew members; she refused, citing fear of deception and language barriers. SAUDIA then barred her from Jakarta flights and later transferred her to Manila in September 1990. On January 14, 1992, and again on June 16, 1993, she was summoned to Jeddah under the pretext of routine investigation, detained, escorted to a Saudi court, and pressured to sign Arabic documents. On July 3, 1993, the Saudi court convicted her of adultery, “immoral” dancing, and socializing with male crew, sentencing her to imprisonment and 286 laCase Digest (G.R. No. 122191)
Facts:
- Employment and Overseas Incidents
- In January 1988, Saudi Arabian Airlines (SAUDIA) hired Milagros P. Morada as a flight attendant based in Jeddah. On April 27, 1990, during a layover in Jakarta, two Saudi crew members attempted to rape her; she was rescued and returned to Jeddah. SAUDIA interrogated her, requested her to help secure her assailants’ release, and, upon her refusal, barred her from Jakarta flights.
- In September 1990, Morada was transferred to Manila. Between January 1992 and July 1993, SAUDIA summoned her repeatedly to Jeddah under the pretext of routine investigation, where she was detained, interrogated by Saudi authorities, and ultimately—without prior warning—tried for adultery and other Islamic offenses. In July 1993 she was sentenced to imprisonment and 286 lashes, later dismissed by the Prince of Makkah who deported her; upon return to Manila, SAUDIA terminated her employment without cause.
- Procedural History
- On November 23, 1993, Morada filed a complaint in RTC Quezon City (Civil Case No. Q-93-18394) for actual, moral, and exemplary damages under Articles 19 and 21, New Civil Code. SAUDIA filed multiple motions to dismiss (grounds: no cause of action, improper party, waiver, lack of jurisdiction). The trial court denied dismissal in Orders of August 29, 1994, and February 2, 1995.
- SAUDIA petitioned the Court of Appeals for certiorari and preliminary injunction; CA issued a temporary restraining order, then denied injunctive relief in its September 27, 1995 Resolution, and on April 10, 1996 upheld RTC jurisdiction and Philippine law applicability, ruling certiorari improper. SAUDIA elevated the matter to the Supreme Court via Rule 45 petition.
Issues:
- Whether the Regional Trial Court of Quezon City has jurisdiction to hear and try Civil Case No. Q-93-18394.
- Whether Philippine law or the law of the Kingdom of Saudi Arabia should govern Morada’s tort claim.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)