JAPAN AIRLINES vs. COURT OF APPEALS, ET. AL.

GR No. 18664; August 7, 1998

FACTS
Private respondents boarded a JAL flight in San Francisco, California bound for Manila. It
included an overnight stopover at Narita, Japan at JAL’s expense. Due to the Mt. Pinatubo
eruption, private respondents’ trip to Manila was cancelled. JAL rebooked all the Manila-bound
passengers and paid for the hotel expenses of their unexpected overnight stay. The flight of
private respondents was again cancelled due to NAIA’s indefinite closure. JAL informed the
respondents that it would no longer defray their hotel and accommodation expense during their
stay in Narita. The respondents were forced to pay for their accommodations and meal expenses
for 5 days.

ISSUE
Whether or not JAL has the obligation to shoulder the hotel and meal expenses even if the delay
was caused by force majeure

RULING
When a party is unable to fulfill his obligation because of force majeure, the general rule is that
he cannot be held liable for damages for non-performance. When JAL was prevented from
resuming its flight to Manila due to the effects of the eruption, whatever losses or damages in the
form of hotel and meal expenses the stranded passengers incurred cannot be charged to JAL. The
predicament of the private respondents was not due to the fault or negligence of JAL. JAL had
the duty to arrange the respondents’ flight back to Manila. However, it failed to look after the
comfort and convenience of its passengers when it made the passengers arrange their flight back
to Manila on their own and after waiting in the airport for a whole day.