Singapore Airlines Vs CA

SINGAPORE AIRLINES LIMITED, petitioner, vs.
THE COURT OF APPEALS and PHILIPPINE AIRLINES, respondents

G.R. No. 107356 March 31, 1995
(Topic: Third Party Complaint)
FACTS: Sancho Rayos was an overseas contract worker who had a renewed contract with the Arabian American Oil Company (Aramco) for
the period covering April 16, 1980, to April 15, 1981. Part of Aramco's policy to its employees returning to Dhahran, Saudi Arabia from Manila
are allowed to claim reimbursement for amounts paid for excess baggage of up to 50 kilograms, as long as it is properly supported by receipt.
April 1980 - Rayos took a Singapore Airlines (SIA) flight to report for his new assignment, with a 50-kilogram excess baggage for which he
paid P4,147.50. Aramco reimbursed said. amount upon presentation of the excess baggage ticket.
December 1980 - Rayos learned that he was one of several employees being investigated by Aramco for fraudulent claim and asked his wife
Beatriz in Manila to seek a written confirmation from SIA that he indeed paid for an excess baggage of 50 kilograms.
In SIAs records- mager Johnny Koo notified Beatriz who was assisted by a lawyer and threatened them of filing a lawsuit, that SIA is unable to
issue certification requested by the spouses citing that only 3 kilograms were entered as excess and not 50 kilograms
April 1981 - Aramco gave Rayos his travel documents without a return visa. His employment contract was not renewed.
August 1981 - spouses Rayos, sued SIA for damages stating his non renewal was caused by SIA.
SIA claimed that it was not liable to the Rayoses because the tampering was committed by its handling agent, Philippine Airlines (PAL) and filed a Third
party complaint against PAL.
PAL - countered that its personnel did not collect any charges for excess baggage; that it had no participation in the tampering of any excess baggage
ticket; and that if any tampering was made, it was done by Singapore Airlines personnel.
RTC rendered Judgement in favor of plaintiff Rayoses and held Singapore airlines liable for damages
-
On 3rd party complaint, PAL was also liable to the Rayoses
All parties appealed to the CA

SIAs appeal dismissed for non payment of docket fees
Rayos withdrew appeal when SIA satisfied judgment of RTC and paid P802, 435.00
On the appeal of PAL - claimed that the spouses Rayos had no valid claim against SIA because it was the inefficiency of Rayos which led to the nonrenewal of his contract with Aramco, and not the alleged tampering of his excess bagged ticket.
Petitioner SIA argued that the only issue in the said appeal is whether or not it was entitled to reimbursement from PAL, ( citing the case of Firestone Tire
and Rubber Company of the Philippines v. Tempongko). SIA set up the defense that the excess baggage ticket was indeed tampered with but it was
committed by PAL's personnel.

Appellate court granted PAL's appeal and absolved it from any liability to SIA.
ISSUE: WHETHER OR NOT PETITIONER IS ENTITLED TO REIMBURSEMENT
RULING: YES
There is no question that 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. There are, however, special circumstances present in this case which preclude third-party
defendant PAL from benefiting from the said principle.
However, 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. Here, the defendant and third-party defendant had no common
defense against the plaintiffs' (Rayos) complaint, and they were even blaming each other for the fiasco.
One of the defenses available to SIA was that the plaintiffs had no cause of action, that is, it had no valid claim against SIA. SIA investigated the
matter and discovered that tampering was, indeed, committed, not by its personnel but by PAL's. This became its defense as well as its main
cause of action in the third-party complaint it filed against PAL.
PAL could have used the defense that the plaintiffs had no valid claim against it or against SIA. This could be done indirectly by adopting such a
defense in its answer to the third-party complaint if only SIA had raised the same in its answer to the main complaint, or directly by so stating in
unequivocal terms in its answer to SIA's complaint that SIA and PAL were both blameless
PAL opted to deny any liability which it imputed to SIA's personnel. It was only on appeal in a complete turn around of theory that PAL
raised the issue of no valid claim by the plaintiff against SIA. This simply cannot be allowed.
A third party complaint involves an action separate and distinct from, although related to the main complaint. A third party defendant who feels
aggrieved by some allegations in the main complaint should, should aside from answering the third party complaint, also answer the main
complaint.
In the case at bar, appellate court was in error when it opined that SIA's answer inured to the benefit of PAL for the simple reason that the
complaint and the third-party complaint are actually two separate cases involving the same set of facts which is allowed by the court to be
resolved in a single proceeding only to avoid a multiplicity of actions. Such a proceeding obviates the need of trying two cases, receiving the
same or similar evidence for both, and enforcing separate judgments therefore.
While such a complaint speaks of a single suit, a third-party complaint involves an action separate and distinct from, although related to the main
complaint. A third-party defendant who feels aggrieved by some allegations in the main complaint should, aside from answering the third-party
complaint, also answer the main complaint.

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SINGAPORE AIRLINES LIMITED, petitioner, vs.

THE COURT OF APPEALS and PHILIPPINE AIRLINES, respondents

On 3rd party complaint, PAL was also liable to the Rayoses

All parties appealed to the CA

committed by PAL's personnel.

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