JAPAN AIRLINES v. CA ENRIQUE AGANA

FACTS:

Private respondents were passengers of Japan Airlines (JAL) bound for Manila, but their flight was cancelled due to the Mt. Pinatubo eruption. JAL rebooked their flight, but it was cancelled again due to the continued closure of the Ninoy Aquino International Airport (NAIA). JAL informed the passengers that they would no longer pay for their hotel and accommodation expenses in Narita, Japan. As a result, the private respondents had to pay for their own accommodations and meals from June 16 to June 21, 1991. The private respondents filed a case for damages against JAL, alleging that the airline failed to provide care and comfort by refusing to pay for their expenses during their stay in Narita. The trial court ruled in favor of the private respondents and ordered JAL to pay damages. JAL appealed to the Court of Appeals, which affirmed the trial court's decision with some modifications on the damages awarded. JAL's motion for reconsideration was denied, leading them to file a petition for certiorari before the Supreme Court. The main issue is whether JAL, as a common carrier, has the obligation to shoulder the hotel and meal expenses of its stranded passengers even if the delay was caused by "force majeure."

ISSUES:

  1. Whether JAL, as a common carrier, has the obligation to shoulder the hotel and meal expenses of its stranded passengers until they have reached their final destination, even if the delay was caused by "force majeure."

RULING:

  1. The Supreme Court held that JAL is not required to shoulder the hotel and meal expenses of its stranded passengers during their unexpected stay in Narita, even if the delay was caused by "force majeure." The Court stated that while JAL has the duty to ensure the comfort and convenience of its passengers, this duty does not extend to covering expenses during delays caused by uncontrollable events. A common carrier is not an insurer against all risks and hazards to passengers. In this case, the delay in reaching the final destination was due to the Mt. Pinatubo eruption, which can be considered as "force majeure," and therefore JAL cannot be held liable for the expenses incurred by the passengers during their extended stay in Narita.

PRINCIPLES:

  • A common carrier has the duty to ensure the comfort and convenience of its passengers, but this duty does not extend to covering expenses during delays caused by uncontrollable events ("force majeure").

  • A contract to transport passengers is different in kind and degree from any other contractual relation.