United Airlines Inc. V. CA, G.R. No.

124110, April 20, 2001

Facts:
Aniceto Fontanilla bought from United Airlines 3 visit the U.S.A. tickets from
himself, his wife and his minor son, Mychal, to visit the cities of Washington DC,
Chicago and Los Angeles. All the flights had been confirmed previously by United
Airlines. Having used the first coupon to DC and while at the Washington Dulles
Airport, Aniceto changed their itinerary, paid the penalty for rewriting their tickets
and was issued tickets with corresponding boarding passes with the words: Checkin-required. They were then set to leave but were denied boarding because the
flight was overbooked.
The CA ruled that private respondents failure to comply with the check-in
requirement will not defeat his claim as the denied boarding rules were not
complied with applying the laws of the USA, relying on the code of Federal
Regulation Part on Oversales of the USA.
Issue: WON the CA is correct in applying the laws of USA
Ruling:
No. According to the doctrine of lex loci contractus, the law of the place
where a contract is made or entered into governs with respect to its nature and
validity, obligation and interpretation shall govern. This has been said to be the rule
even though the place where the contract was made is different from thr place
where the airline ticket was issued, where the passengers are residents and
nationals of the forum and the ticket is issued in such State by the defendant
airline. Therefore, although, the contract of carriage was to be performed in the
United States, the ticket were purchased through petitioners agent in manila.