Case Summary (G.R. No. 84330)
Applicable Law
The relevant legal framework for this case includes the provisions of the Warsaw Convention regarding air transportation contracts and the Civil Code of the Philippines related to contract breaches and the awarding of damages.
Contract of Carriage and Breach
The Court found that Lufthansa had entered into a contract of carriage with Antiporda, evidenced by the issuance of a confirmed ticket for his entire trip to Blantyre, Malawi. The lower court concluded that Lufthansa breached this contract by failing to ensure Antiporda was transported to his destination, holding that Lufthansa could not limit its liability, based on the terms confirmed in the ticket.
Arguments from Lufthansa
Lufthansa contended that it acted merely as a ticket-issuing agent for Air Kenya, thus asserting that its liability was limited to the segments of the journey it operated, i.e., from Manila to Bombay, denying responsibility for the subsequent legs of the trip. Additionally, it argued for the applicability of certain provisions of the Warsaw Convention, which restrict carrier liability to occurrences on their own lines.
Court Rulings
The Regional Trial Court ruled against Lufthansa, holding it responsible for the breach, and reinforced this with references to the International Air Transport Association (IATA) and previous Supreme Court decisions that affirmed an airline's responsibility across successive carriers for confirmed itineraries. The Court of Appeals upheld this ruling, reasoning that Antiporda entered a single, continuous contract with Lufthansa, which remained liable for honoring the entirety of the flight arrangements.
Lufthansa's Appeal and Court Findings
On appeal, the Supreme Court affirmed the decisions of the lower courts, focusing on the assurances provided by Lufthansa through the issuance of the confirmed ticket. The Court emphasized that Lufthansa, by confirming the connecting flight, effectively guaranteed Antiporda's transport through Air Kenya, thus cementing its responsibility despite the involvement of other air carriers.
Damages Awarded
The lower court awarded Antiporda ₱300,000 in moral damages, ₱200,000 in exemplary damages, and ₱50,000 for attorney's fees, which was affirmed by the appellate court on the basis of the airline's bad faith and the manner in
...continue readingCase Syllabus (G.R. No. 84330)
Case Overview
- The case revolves around a petition for review on certiorari involving Lufthansa German Airlines and private respondent Tirso V. Antiporda, Sr., concerning a breach of contract of carriage due to Antiporda being "bumped off" a flight.
- Antiporda, a well-regarded financial specialist, was contracted for a project in Malawi and issued a confirmed ticket for his travels, which included multiple legs with different airlines.
Background of the Parties
Tirso V. Antiporda, Sr.:
- An associate director of the Central Bank of the Philippines.
- A registered consultant for various international financial institutions.
- Engaged as an independent contractor for a project in Malawi with SGV.
- Was provided a round-trip economy ticket and other allowances for his engagement.
Lufthansa German Airlines:
- Issued a confirmed ticket for Antiporda's five-leg journey to Malawi.
- Contended that its responsibility ceased at a certain point in the journey, claiming it was merely a ticket-issuing agent for Air Kenya.
Incident Leading to the Case
- On September 25, 1984, Antiporda began his journey, successfully traveling from Manila to Singapore and then to Bombay.
- Upon arrival in Bombay, he was informed that he would not be allowed to board the connecting flight to Nairobi due to overbooking, as his seat was given to another passenger.
- Antiporda protested but was ultimately stranded for over 32 hours before being rebooked to Nairobi via Addis Ababa, arriving late to Malawi.
Legal Proceedings
- Antiporda's counsel demanded damages from Lufthansa, leadin