Japan Airlines vs Court of Appeals (G.R. No.

118664)
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.

Issues:

1. Whether or not JAL has the obligation to shoulder the hotel and meal expenses even if
the delay was caused by force majeure
2. Whether or not the award of damages was proper
Held:

1. 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.
2. Yes, the award of nominal damages is proper. Nominal damages are adjudicated in order
that a right of a plaintiff, which has been violated or invaded by the defendant, may be
vindicated or recognized and not for the purpose of indemnifying any loss suffered by
him.