Singapore Airlines vs.

CA and Philippine Airlines

FACTS:

 Sancho Rayos was an overseas contract worker who had a renewed contract with the Arabian
American Oil Company (Aramco). As part of Aramco's policy, 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.
 Rayos took a Singapore Airlines flight to report for his new assignment, with a 50-kilogram
excess baggage for which he paid; Aramco reimbursed said amount upon presentation of the
excess baggage ticket.
 Rayos learned that he was one of several employees being investigated by Aramco for
fraudulent claims. He immediately asked his wife Beatriz in Manila to seek a written
confirmation from SIA that he indeed paid for an excess baggage of 50 kilograms
 SIA belatedly said that records showed that only three kilograms were entered as excess and
accordingly charged thus Aramco gave Rayos his travel documents without a return visa. His
employment contract was not renewed.
 The spouses Rayos, convinced that SIA was responsible for the non-renewal of Rayos'
employment contract with Aramco, sued it for damages
 SIA claimed that it was not liable to the Rayoses because the tampering was committed by its
handling agent, Philippine Airlines (PAL). It then filed a third-party complaint against PAL. PAL, in
turn, 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
 RTC ruled that SIA should pay Rayos while PAL should pay SIA whatever the latter has paid the
plaintiffs. RTC concluded that the excess baggage ticket of Rayos was tampered with by the
employees of PAL and that the fraud was the direct and proximate cause of the non-renewal of
Rayos' contract with Aramco
 SIA's appeal was dismissed for non-payment of docket fees while Sps. Rayos withdrew their
appeal when SIA satisfied the judgment: PAL claimed that the Sps. Rayos had no valid claim
against SIA because it was the inefficiency of Rayos which led to the non-renewal of his contract
with Aramco
 CA disagreed with SIA's contention that PAL could no longer raise the issue of SIA's liability to
the Rayoses and opined "that SIA's answer to the complaint should inure to the benefit of PAL,
and the latter may challenge the lower court's findings against SIA in favor of plaintiffs-appellees
(the Rayos spouses) for the purpose of defeating SIA's claim against it, and not for the purpose
of altering in any way the executed judgment against SIA." In its answer to the main complaint,
SIA set up the defense that the excess baggage ticket was indeed tampered with but it was
committed by PAL's personnel. CA granted PAL's appeal and absolved it from any liability to SIA.

ISSUE:

WON the CA should have restricted its ruling on the right of SIA to seek reimbursement from PAL, as this
was the only issue raised by SIA in its third-party complaint against PAL.

HELD:
YES. The case of Firestone squarely applies to the case at bench. In said case, the Court expounded on
the nature of a third-party complaint and the effect of a judgment in favor of the plaintiff against the
defendant and in favor of such defendant as third-party plaintiff against, ultimately, the third-party
defendant. The Court stated:

The third-party complaint is actually independent of and separate and distinct from the plaintiff's complaint. When 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. When he finds favorably on both complaints, as in
this case, he renders judgment on the principal complaint in favor of plaintiff against defendant and renders another
judgment on the third-party complaint in favor of defendant as third-party plaintiff, ordering the third-party defendant
to reimburse the defendant whatever amount said defendant is ordered to pay plaintiff in the case. Failure of any of said
parties in such a case to appeal the judgment as against him makes such judgment final and executory.

It must be noted that in the proceedings, PAL disclaimed any liability to the Rayos and imputed the
alleged tampering to SIA's personnel. On appeal, however, PAL changed its theory and averred that the
spouses Rayos had no valid claim against SIA on the around that the non-renewal of Sancho's contract
with Aramco was his unsatisfactory performance. In response to PAL's appeal, SIA argued that it was
improper for PAL to question SIA's liability to the plaintiff, since this was no longer an issue on account
of the finality and, in fact, satisfaction of the judgment.

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.

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. For its part, PAL could have used the defense that the plaintiffs had no
valid claim against it or against SIA Yet, 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.

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' complaint, and they were even blaming each other.

The judgment, therefore, as far as the Rayoses and SIA are concerned, has already gained finality. What
remains to be resolved, as correctly pointed out by petitioner, is whether it is entitled to reimbursement
from PAL, considering that PAL appealed that part of the decision to the appellate court. This is where
the rule laid down in Firestone becomes applicable.

The trial court's decision, although adverse to SIA as defendant, made PAL ultimately answerable for the
judgment by ordering the latter to reimburse the former for the entire monetary award. On appeal, PAL
tried to exonerate itself by arguing that the Rayoses had no valid claim against SIA, this seemed to be
the only way to extricate itself from a mess which the court a quo ascribed to it. This cannot, however,
be allowed because it was neither raised by SIA in its answer to the main complaint nor by PAL in its
answer to the third-party complaint.
CA erred when it discourse that SIA's answer accustom 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
action. This situation is not, as claimed by the appellate court, analogous to a case where there are
several defendants against whom a complaint is filed stating a common cause of action, where the
answer of some of the defendants inures to the benefit of those who did not file an answer. 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.

SC do not, however, agree with the petitioner that PAL is solely liable for the satisfaction of the
judgment for SIA failed to consider that 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.

Former Chief Justice and noted remedial law expert Manuel V. Moran opined that "in an action upon a
tort, the defendant may file a third-party complaint against a joint tort-feasor for contribution." The
non-renewal of Rayos employment contract was the natural and probable consequence of the separate
tortious acts of SIA and PAL.

SC ordered private respondent Philippine Airlines to pay, by way of contribution, petitioner Singapore
Airlines one-half (1/2) of the amount it actually paid to Sancho and Beatriz Rayos in satisfaction of the
judgmen