Case Digest (G.R. No. L-6409) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Aboitiz Shipping Corporation v. Court of Appeals, the heirs of Anacleto Viana sued petitioner Aboitiz Shipping Corporation for damages after Viana’s death aboard M/V Antonia. On May 11, 1975, Viana purchased a ticket and boarded the vessel at San Jose, Occidental Mindoro. The next day, M/V Antonia docked at Pier 4, North Harbor, Manila. Although a gangplank connected ship to pier, Viana disembarked on the third deck, level with the dock. One hour later, Pioneer Stevedoring Corporation, under a stevedoring contract with Aboitiz, began unloading cargo using its crane. Remembering undelivered cargo, Viana returned aboard and was pointing out his goods to crew when the moving crane crushed him against the vessel. He was hospitalized and died on May 15, 1975, from complications of a traumatic pelvic fracture. His widow spent ₱9,800 on expenses, alleged moral damages and hired counsel for ₱10,000. The trial court held Aboitiz liable for breach of contract of carriage and ordered Pi Case Digest (G.R. No. L-6409) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- Petitioner: Aboitiz Shipping Corporation (“Aboitiz”), carrier of M/V Antonia.
- Private respondents: Lucila C. Viana, spouses Antonio and Gorgonia Viana (“the Vianas”), heirs of deceased passenger Anacleto Viana.
- Third-party defendant: Pioneer Stevedoring Corporation (“Pioneer”), arrastre contractor under Memorandum of Agreement of July 26, 1975.
- Accident and Consequences
- Voyage and disembarkation
- May 11–12, 1975: Anacleto boarded at San Jose, Occidental Mindoro, for Manila; purchased ticket for ₱23.10.
- Vessel docked Pier 4, North Harbor; gangplank provided but passenger used third-deck exit.
- Crane operation and fatal injury
- One hour after passenger disembarkation, Pioneer’s crane began unloading cargo.
- Anacleto re-boarded to point out his cargo; crane struck him, pinning him against vessel.
- He was hospitalized (hypostatic pneumonia secondary to traumatic fracture with bladder laceration) and died May 15, 1975.
- Expenses and losses
- Medical, burial and miscellaneous: ₱9,800.00.
- Estimated unearned income: 400 cavans of palay/year as farm supervisor; support to parents 20 cavans/month.
- Mental anguish, moral damages, and attorney’s fees of ₱10,000.00.
- Pleadings and Trial Court Proceedings
- Complaint by Vianas: breach of contract of carriage; damages for death and other losses.
- Aboitiz’s answer: denied liability; vessel under Pioneer’s control; invoked fellow-servant rule.
- Third-party complaint by Aboitiz vs. Pioneer: negligence of crane operator.
- Trial court decision (Apr 17, 1980): Aboitiz liable; Pioneer ordered to reimburse.
- Trial court modification (Oct 27, 1982): Pioneer absolved for lack of proven negligence; Aboitiz liability maintained.
- Court of Appeals (July 29, 1988): affirmed modified trial court judgment; adjusted damage amounts.
- Petition for certiorari filed by Aboitiz before the Supreme Court.
Issues:
- Whether Anacleto Viana remained a “passenger” of Aboitiz at time of accident, invoking the La Mallorca doctrine.
- Whether Aboitiz, as common carrier, is liable for death under breach of contract of carriage despite contributory negligence.
- Whether Aboitiz may recover from Pioneer under its third-party complaint for amounts paid the Vianas.
- Whether the presumption of carrier negligence was rebutted by Aboitiz’s precautionary measures.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)