Title
Addenbrooke vs. Natividad
Case
G.R. No. 16172
Decision Date
Dec 13, 1921
A motor yacht, "Cecilia," used for pleasure, was deemed a "steam vessel" under the Administrative Code, requiring a licensed patron for safety, despite its internal combustion engine.
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Case Digest (G.R. No. 16172)

Facts:

    Background of the Parties

    • Plaintiff: J. J. J. Addenbrooke, a resident of Cebu and owner of the motor yacht Cecilia.
    • Defendant: Joaquin Natividad, Collector of Customs for Cebu.

    Description of the Vessel

    • The Cecilia is a motor yacht of approximately 22 tons gross.
    • It is powered by an internal combustion engine (oil burning) rather than by steam.
    • The yacht is operated exclusively for pleasure and recreation, not for carrying passengers or freight for profit.

    Regulatory Basis and Controversy

    • The defendant required the plaintiff to have a licensed patron (master) in charge of the vessel as mandated by subsection (e) of section 1203 of the Administrative Code, which stipulates the required complement of officers.
    • The law, as written, applies to “every vessel registered in the Philippine Islands” and classifies registered vessels as either steam vessels or sailing vessels.
    • There is no explicit category for motor boats, leading to the question of whether a motor yacht like the Cecilia should be considered a steam vessel for regulatory purposes.

    Legal Proceedings

    • The plaintiff filed an action in the Court of First Instance of Cebu for a perpetual injunction to prevent the enforcement of the licensing requirement.
    • A favorable judgment was rendered in favor of the plaintiff at the trial level.
    • The defendant subsequently appealed the decision.

    Statutory and Regulatory References

    • Section 1419 of the Administrative Code defines “vessel” to include all manners of artificial contrivances used or capable of being used for water transportation.
    • Section 1167 mandates the registration of vessels of more than 3 tons gross in Philippine waters.
    • Section 1203, from which the requirement in question is derived, only recognizes the categories of steam vessels and sailing vessels, leaving motor boats as a casus omissus.
    • Customs Marine Circular No. 53 (October 22, 1912) defined “steam vessel” to include any vessel propelled by machinery, an interpretation that was widely accepted, including in American jurisprudence (e.g., The Nimrod case).

Issue:

    Classification of the Vessel

    • Whether a motor yacht propelled by an internal combustion engine should be classified as a “steam vessel” under the language of section 1203 of the Administrative Code.

    Applicability of Officer Complement Requirements

    • Whether the statutory requirement to have one patron in the minor coastwise trade applies to a vessel used exclusively for pleasure and recreation.
    • The interpretation of the phrase "in the minor coastwise trade" as a classification of the officer rather than an indication of the vessel's commercial purpose.

    Legislative Intent and Regulatory Consistency

    • How the historically established Customs Marine Regulations impact the modern interpretation of the law.
    • Whether the omission of a separate category for motor boats indicates legislative intent to subsume them under the category of steam vessels.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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