Case Digest (G.R. No. 211876) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Asian Terminals, Inc. (ATI) v. Padoson Stainless Steel Corporation (Padoson), decided on June 25, 2018 under the 1987 Constitution, Padoson engaged ATI on October 5 and October 30, 2001 to render arrastre, wharfage, and storage services for nine stainless steel coils and 72 hot-rolled steel coils at South Harbor, Port of Manila. A Bureau of Customs (BOC) Hold-Order dated September 7, 2001 arose from Padoson’s tax liability in a separate Customs case before RTC Manila, Branch 173. The shipments remained in ATI’s premises until their withdrawal on July 29, 2006. ATI repeatedly demanded P540,474.48 and P8,374,060.80 for storage fees, but Padoson defaulted. On August 4, 2006, ATI filed Civil Case No. 06-115638 in RTC Manila, Branch 41, praying for payment of P8,914,535.28 plus legal interest, exemplary damages, and attorney’s fees. Padoson counterclaimed, alleging that ATI’s negligence caused deterioration and loss of the shipments, substantiated by Customs-case documents and unm Case Digest (G.R. No. 211876) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Background
- Asian Terminals, Inc. (ATI) was contracted by Padoson Stainless Steel Corporation (Padoson) to provide arrastre, wharfage, and storage services for two shipments (9 stainless steel coils; 72 hot-rolled steel coils) imported October 5 and 30, 2001, stored until July 29, 2006.
- On September 7, 2001, the Bureau of Customs (BOC) issued a Hold-Order on the shipments in connection with Padoson’s tax‐liability case (Civil Case No. 01-102440) before RTC Manila Branch 173.
- Claims and Counterclaims
- ATI demanded P8,914,535.28 plus legal interest, P100,000 exemplary damages, and P100,000 attorney’s fees; filed a Complaint for Sum of Money and Damages (Aug. 4, 2006) before RTC Manila Branch 41 (Civil Case No. 06-115638).
- Padoson counterclaimed that shipments deteriorated under ATI’s custody: presented ocular‐inspection reports, sheriff’s returns, and photographs; alleged loss of one stainless coil (P882,000) and depreciation/lost profits totaling P13.8 million (hot-rolled) and P2,110,000 (remaining stainless).
- Trial and Lower Court Decisions
- The RTC disallowed Padoson’s unmarked photographs and testimony of the photographer; ATI’s witness testified on computation of storage fees.
- RTC Decision (July 16, 2012) dismissed ATI’s complaint and Padoson’s counterclaim, ruling that BOC had “constructive possession” via the Hold-Order and, not being impleaded, could not be held liable; CA affirmed (July 23, 2013) and denied reconsideration (Mar. 26, 2014).
Issues:
- Liability for Storage Fees
- Does BOC’s Hold-Order vest “constructive possession” in BOC, relieving Padoson and making BOC liable for ATI’s storage fees?
- Can Padoson shift its payment obligation to BOC without impleading it?
- Negligence and Damages
- Did Padoson prove that shipments deteriorated due to ATI’s lack of extraordinary diligence?
- Is ATI liable for damages—exemplary or otherwise—and are attorney’s fees warranted?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)