Thursday, March 14, 2024

Case Digest: Sabena Belgian vs. Court of Appeals, 255 SCRA 38, G.R. No. 104685

 

Sabena Belgian vs. Court of Appeals, 255 SCRA 38, G.R. No. 104685, March 14, 1996

Subject: Transportation Law


FACTS

On August 21, 1987, plaintiff was a passenger on board Flight SN 284 of defendant airline originating from Casablanca to Brussels, Belgium on her way back to Manila. Plaintiff checked in her luggage which contained her valuables, namely: jewelry valued at $2,350.00; clothes $1,500.00 shoes/bag $150; accessories $75; luggage itself $10.00; or a total of $4,265.00, for which she was issued Tag No. 71423. She stayed overnight in Brussels and her luggage was left on board Flight SN 284.

Plaintiff arrived at Manila International Airport on September 2, 1987 and immediately submitted her Tag No. 71423 to facilitate the release of her luggage but the luggage was missing. She was advised to accomplish and submit a property Irregularity Report which she submitted and filed on the same day.

She followed up her claim on September 14, 1987 but the luggage remained to be missing.

On September 15, 1987, she filed her formal complaint with the office of Ferge Massed, defendant's Local Manager, demanding immediate attention.

On September 30, 1987, on the occasion of plaintiffs following up of her luggage claim, she was furnished copies of defendant's telexes with an information that the Burssel's Office of defendant found the luggage and that they have broken the locks for identification. Plaintiff was assured by the defendant that it has notified its Manila Office that the luggage will be shipped to Manila on October 27, 1987. But unfortunately plaintiff was informed that the luggage was lost for the second time.

At the time of the filing of the complaint, the luggage with its content has not been found.

Plaintiff demanded from the defendant the money value of the luggage and its contents amounting to $4,265.00 or its exchange value, but defendant refused to settle the claim.

ISSUE

Whether or not petitioner is liable for the loss even though respondent was not able to declare the valuables.

RULING

Yes, the petitioner is liable for the loss even though the respondent was not able to declare the valuables. 

Under the law that from the very nature of their business and by reasons of public policy, common carriers are bound to observe extraordinary diligence in the vigilance over the goods transported by them. This extraordinary responsibility, according to Art. 1736, lasts from the time the goods are unconditionally placed in the possession of and received by the carrier until they are delivered actually or constructively to the consignee or person who has the right to receive them. Art. 1737 states that the common carrier's duty to observe extraordinary diligence in the vigilance over the goods transported by them remains in full force and effect even when they are temporarily unloaded or stored in transit. And Art. 1735 establishes the presumption that if the goods are lost, destroyed or deteriorated, common carriers are presumed to have been at fault or to have acted negligently, unless they prove that they had observed extraordinary diligence

In this case, remained undisputed that private respondent's luggage was lost while it was in the custody of petitioner. Given all the facts, SC sustained the trial court’s finding that the petitioner is ultimately guilty of "gross negligence" in the handling of private respondent's luggage. The "loss of said baggage not only once but twice. It underscores the wanton negligence and lack of care on the part of the carrier.

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