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SINGAPORE AIRLINES LTD vs.

CA TOPIC: RULE 6

MARCH 31, 1995


PETITION FOR REVIEW ON CERTIORARI
PETITIONER: SINGAPORE AIRLINES LIMITED
RESPONDENTS: CA & PHILIPPINE AIRLINES

FACTS: Sancho Rayos, an OFW working for Arabian American Oil Company (Aramco)
claimed reimbursement from the latter for amounts he paid for a 50-kg excess baggage on a
Singapore Airlines (SIA) flight to Saudi Arabia; company policy allows such reimbursements.
Later, Rayos was investigated by Aramco for fraudulent claims in relation to his
reimbursement. Rayos then asked his wife to seek a written confirmation from SIA that he
indeed paid for an excess baggage of 50 kg. SIA initially replied that they are unable to issue
said certification because their records showed that only 3 kg were entered as excess and
accordingly charged. It eventually issued the certification after 4 months, upon threat of a
lawsuit. However, Rayos’ contract was not renewed by Aramco.

PETITIONER COURT RESPONDENT


Sps Rayos filed a Complaint for Damages against SIA

THIRD PARTY RTC MANILA


(Denied liability)
COMPLAINT COMPLAINT FOR DAMAGES:
(vs PAL) IN FAVOR OF SPS RAYOS
 PAL, its handling agent, (ordered SIA to pay Sps Rayos)
actually committed the
tampering THIRD-PARTY COMPLAINT:
IN FAVOR OF SIA
(ordered PAL to pay SIA the
amount it paid to Sps Rayos)

APPEAL CA
(SIA’s liability to Rays no DISMISSED SIA’s APPEAL
longer an issue on appeal; (nonpayment of docket fees) APPEAL
judgment final and (Rayos without valid claim
executory; only issue is GRANTED PAL’s APPEAL against SIA)
WON it was entitled to (SIA’s answer to the Complaint
reimbursement from PAL) should inure to the benefit of
PAL, which PAL could use to
challenge the RTC ruling)
PETION FOR REVIEW ON
CERTIORARI
 PAL cannot assail for the SC:
first time on appeal RTC GRANTED
decision sustaining the (PAL ordered to pay SIA only
validity of Sps Rayos’ half the amount it paid to Sps
complaint against SIA if Rayos)
PAL did not raise the same
in the RTC

BAUTISTA │ ESTERON │ HIPOLITO │ MANANTAN | RAMIREZ │ PIOQUINTO │ SALES | YAMO 3-EVE


SINGAPORE AIRLINES LTD vs. CA TOPIC: RULE 6

RATIO:
1. Firestone case: Nature of a third-party complaint
 Definition: a procedural device whereby a “third party” who is neither a party nor
privy to the act or deed complained of by the plaintiff, may be brought into the case
with leave of court, by the defendant, who acts as third-party plaintiff to enforce
against the third-party defendant a right for contribution, indemnity, subrogation or
any other relief, in respect of the plaintiff’s claim
 Independent of and separate and distinct from the plaintiff’s complaint
 When the leave to file the third party complaint is properly granted, the Court
renders in effect two judgments in the same case, one on the plaintiff’s complaint
and the other on the third-party complaint;
 An appeal by one party from such judgment does not inure to the benefit of the
other party who has not appealed nor can it be deemed to be an appeal of such other
party from the judgment against him
 Rule: a third-party defendant is allowed to set up in his answer the defenses which
the third-party plaintiff (original defendant) has or may have to the plaintiff’s claim
2. Special circumstances in this case preclude PAL from setting up the defenses which SIA has
or may have to the plaintiff’s claim
 PAL opted to deny liability in its defense to the third-party complaint, imputing
liability to SIA’s personnel; it was only on appeal that PAL raised the issue of no
valid claim by the Sps Rayos against SIA  cannot be allowed
 While the third-party defendant would benefit from a victory by the third-party
plaintiff against the plaintiff, this is true only when the third-party plaintiff and
third-party defendant have non-contradictory defenses
o Here, SIA and PAL had no common defense against the plaintiff’s complaint,
even had contradictory defenses
o PAL should have answered the main complaint aside from answering the
third-party complaint// SIA’s answer to the main complaint did not inure to
PAL’s benefit as the two complaints are two separate cases
3. Sps Rayos entitled to reimburse from both SIA and PAL
 Proximate cause of Rayos’ non-renewal of employment was the tampering of his
excess baggage ticket by PAL’s personnel; however, the immediate cause of such
non-renewal was SIA’s delayed transmittal of the certification needed by Rayos to
prove his innocence to his employer (4 months after it was informed)
 Rayos’ non-renewal was the natural and probable consequence of the separate
tortious acts of SIA and PAL; both should be liable in equal amounts

BAUTISTA │ ESTERON │ HIPOLITO │ MANANTAN | RAMIREZ │ PIOQUINTO │ SALES | YAMO 3-EVE