Short answer. Generally not liable under this article. Article 2000 of the Civil Code makes hotel-keepers responsible for loss or injury to a guest's property caused by their servants, employees, or strangers, but the article expressly excludes loss proceeding from any force majeure — and a typhoon is the kind of event ordinarily treated as force majeure.
What the law says
The responsibility referred to in the two preceding articles shall include the loss of, or injury to the personal property of the guests caused by the servants or employees of the keepers of hotels or inns as well as strangers; but not that which may proceed from any force majeure.
Civil Code, Article 2000 — Scope of Hotel-Keeper Liability. Read the full provision →
What the law says
The fact that travellers are constrained to rely on the vigilance of the keeper of the hotels or inns shall be considered in determining the degree of care required of him.
Civil Code, Article 2000 — Scope of Hotel-Keeper Liability. Read the full provision →
What Article 2000 makes hotel-keepers responsible for
Article 2000 provides that a hotel-keeper's responsibility shall include the loss of, or injury to the personal property of the guests caused by the servants or employees of the keepers of hotels or inns as well as strangers. This liability is centered on loss caused by people — staff, employees, or outsiders acting within the hotel — rather than on every possible cause of loss a guest's belongings might suffer while at the hotel.
The force majeure exclusion
The same sentence carves out an express exception: but not that which may proceed from any force majeure. A typhoon is generally treated as the kind of extraordinary natural event that qualifies as force majeure — an occurrence beyond human control and foresight that the hotel did not cause and could not have prevented. Loss of your luggage that genuinely proceeded from the typhoon's flooding, rather than from anyone's act, falls within this exclusion rather than within the article's basic liability.
The degree-of-care consideration that still applies
Article 2000 also states that the fact that travellers are constrained to rely on the vigilance of the keeper of the hotels or inns shall be considered in determining the degree of care required of him. This means the hotel's own conduct before and during the typhoon — how it prepared for and responded to the danger — can still matter to what degree of care was expected of it, even where the ultimate cause of the loss was the typhoon itself.
What this article does not resolve
Article 2000 sets out the general liability and the force majeure exclusion, but it does not itself define exactly what qualifies as force majeure in every circumstance, or address a situation where the hotel's own negligence — such as failing to take reasonable precautions against a foreseeable flood — combined with the typhoon to cause or worsen the loss. Whether that kind of overlap applies to your situation depends on the specific facts of what the hotel did or failed to do.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Sulpicio Lines, Inc. vs. Napoleon Sesante, et al, G.R. No. 172682, July 27, 2016 — read the decision on LawPhil →