Case Digest (G.R. No. 107356)
Facts:
Singapore Airlines Limited v. The Court of Appeals and Philippine Airlines, G.R. No. 107356, March 31, 1995, Supreme Court Third Division, Romero, J., writing for the Court.
Sancho Rayos was an overseas contract worker whose Aramco employment covered April 16, 1980 to April 15, 1981. Under Aramco policy, returning employees presenting receipts could be reimbursed for excess baggage up to 50 kilograms. On April 13, 1980, Rayos flew on Singapore Airlines (SIA) carrying 50 kilograms of excess baggage for which he paid P4,147.50; Aramco reimbursed him on presentation of the excess-baggage ticket.
In December 1980 Aramco began investigating several employees, including Rayos, for allegedly fraudulent claims. Rayos asked his wife Beatriz to obtain a written confirmation from SIA that he had indeed paid for 50 kilograms of excess baggage. On December 10, 1980, SIA’s manager Johnny Khoo informed Beatriz that SIA’s records reflected only three kilograms of excess and that SIA could not certify the 50-kg charge. SIA issued the requested certification only on April 8, 1981 after an internal investigation and after Beatriz—assisted by counsel—threatened suit. On April 14, 1981 Aramco returned Rayos’ travel documents without a return visa and did not renew his contract.
On August 5, 1981, Sancho and Beatriz Rayos sued SIA for damages, alleging that tampering with the excess-baggage ticket caused the non-renewal. SIA defended that its handling agent, Philippine Airlines (PAL), had tampered with the ticket and filed a third‑party complaint against PAL. PAL denied collecting any excess-baggage charge or participating in tampering and imputed the tampering to SIA’s personnel.
The Regional Trial Court, Manila, Branch 30 (Judge Jesus O. Ibay) rendered judgment on September 9, 1988 in favor of the Rayoses, awarding actual, moral damages, reimbursement of P4,147.50, attorney’s fees, and costs; it dismissed SIA’s counterclaim and ordered third‑party defendant PAL to pay SIA whatever SIA had been ordered to pay the plaintiffs. All parties appealed to the Court of Appeals. SIA’s appeal to the CA was dismissed for non‑payment of docket fees, a dismissal this Court later sustained; the Rayoses withdrew their appeal when SIA satisfied the judgment. On September 21, 1992 the Court of Appeals granted PAL’s appeal and absolved PAL from liability to SIA.
SIA filed the present petition for re...(Pro-only)
Issues:
- May a third‑party defendant (PAL) for the first time on appeal attack the plaintiff’s cause of action against the original defendant (SIA) by raising defenses not pleaded in the trial court or in its answer to the third‑party complaint?
- If PAL is liable, in what manner and proportion must PAL reimburse or contribute to SIA for the amount SIA paid the Rayose...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)