G.R. No. 258456 - Aggabao vs. Commission on Elections

Petitioner: Aboitiz Shipping Corporation, a corporation organized and operating under Philippine laws engaged in maritime trade as a common carrier.
Respondent: General Accident Fire and Life Assurance Corporation, Ltd. (GAFLAC), a foreign insurance company acting as subrogee for several cargo consignees whose cargo was lost with the vessel.

The vessel, MV P. Aboitiz, was a common carrier owned and operated by petitioner.
The vessel sank on October 31, 1980, while voyaging from Hongkong to the Philippines.
The sinking gave rise to multiple suits by shippers, successor-in-interest, and cargo insurers seeking recovery of lost cargo and other damages.

The Regional Trial Court (RTC) of Manila, Branch IV, in Civil Case No. 144425 issued an Order on April 30, 1991 granting execution to GAFLAC for the full amount of the judgment award.
Petitioner opposed the execution based on the real and hypothecary nature of its liability as a ship owner, arguing that maritime law provides a doctrine of limited liability.
The Court of Appeals dismissed petitioner’s petition for certiorari challenging the RTC’s Order and affirmed the decision in Civil Case No. 144425.
Subsequently, the issue was elevated to the Supreme Court on a petition for review, as shown in G.R. No. 89757, where the lower court’s factual findings and conclusions were upheld.

The Board of Marine Inquiry (BMI Case No. 466, December 26, 1984) had earlier found that the sinking resulted from force majeure and that the vessel was seaworthy at the time of the incident.
Notwithstanding the BMI findings, the trial court held that the loss did not occur due to force majeure, thus awarding GAFLAC’s claim.
Contrasting rulings in other cases (including G.R. No. 100373) upheld the BMI’s findings regarding seaworthiness and force majeure, thereby creating an apparent conflict in factual determinations.
The petition seeks to resolve whether the limited liability doctrine—as based on maritime law’s real and hypothecary nature—should apply to all claims relating to the sinking.

The Limited Liability Rule warrants a stay on the execution of the judgment to protect the interests of other creditors by preventing premature depletion of assets.
A finding of unseaworthiness is not necessarily attributable to the shipowner, especially where the negligence of the crew or captain may be implicated.
The principle of “Law of the Case” should not automatically bar the petition’s merit regarding limited liability claims.

There is no applicable limited liability under the relevant provisions of the Code of Commerce (Articles 587, 590, and 837) given the established facts and previous rulings in Civil Case No. 144425 and G.R. No. 89757.
The doctrine of the “Law of the Case” should bind all related incidents, ensuring uniformity and precluding any deviation from the established rulings.

Examination of the Resolution in G.R. No. 88159 revealed that it addressed limited liability within the context of package limitation clauses in bills of lading and issues of primary administrative jurisdiction, rather than the limited liability arising from maritime law’s real and hypothecary nature.
The main issue is whether the respondent court erred in granting execution of the full judgment award, effectively bypassing the application of the limited liability rule provided under maritime law.

Whether or not the execution of the full judgment award in Civil Case No. 144425 should be stayed pending the determination and consolidation of all claims arising from the sinking of MV P. Aboitiz.
Whether the limited liability doctrine under the real and hypothecary nature of maritime law applies to the claims against petitioner.

Whether the Resolution in G.R. No. 88159 (relating to package limitation clauses) bars or precludes the current petition regarding maritime limited liability.
Whether it is proper for the Court to mandate a distribution (or limitation and distribution) action to ensure pro-rata sharing of the insurance proceeds and pending freightage among all claimants.
Whether the execution of judgments that have already become final and executory may be stayed in situations where enforcing them would prejudice other creditors’ rights.

The need to prevent the premature depletion of assets that would prejudice the rights of claimants who have yet to file or complete their cases.
The proper invocation and application of the doctrines of limited liability and the “Law of the Case” in reconciling contrary rulings from related cases.