UNITEDAIRLINES Vs CA
UNITEDAIRLINES Vs CA
UNITEDAIRLINES Vs CA
FACTS: Aniceto Fontanilla bought from United Airlines, through the Philippine Travel Bureau in Manila,
three “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 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: “Check-in-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-inrequirement 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 Over sales of the USA.
HELD: 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 the place where it is to be performed. Hence, the court should apply the
law of the 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 tickets were
purchased through petitioner’s agent in Manila. It is true that the tickets were "rewritten" in
D.C., however, such fact did not change the nature of the original contract of carriage entered into by
the parties in Manila.