Tort

If the passenger’s cause of action against the airline company is premised onculpa aquiliana or quasi-delict for a tort committed by the employee of the airline company’s agent, there must be an independent showing that the airline company was at fault or negligent or has contributed to the negligence or tortuous conduct committed by the employee of its agent (Sps. Fernando and Lourdes Viloria Vs. Continental Airlines, Inc., G.R. No. 188288. January 16, 2011).