Case Digest (G.R. No. 120670) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On October 25, 1995, Contiquincybunge Export Company loaded 6,843.700 metric tons of U.S. soybean meal in bulk aboard the M/V aSea Dreama at Port Darrow, Louisiana, U.S.A., consigned to Simon Enterprises, Inc. in Manila. Upon discharge at South Harbor, respondent claimed receipt of only 6,825.144 metric tons, or a shortage of 18.556 metric tons. On November 25, 1995, Contiquincybunge shipped another 3,300.000 metric tons aboard the M/V aTerna under a clean Berth Term Grain Bill of Lading, delivered January 25, 1996, to the same consignee. Respondent reported only 3,100.137 metric tons received, a deficit of 199.863 metric tons. After claims to the carrier and arrastre operator Asian Terminals, Inc. (“ATI”) were denied, respondent filed suit on December 3, 1996, in the RTC of Manila against the unknown vessel owners, their local agent Inter-Asia Marine Transport, Inc., and ATI for damages. A release and quitclaim settled the claim against the first vessel, leaving the aTerna owne Case Digest (G.R. No. 120670) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- First Shipment and Shortage
- On October 25, 1995, Contiquincybunge Export Company loaded 6,843.700 MT of U.S. soybean meal in bulk on M/V Sea Dreama at Darrow, Louisiana, for delivery to Simon Enterprises, Inc. in Manila.
- Upon discharge at South Harbor, respondent claimed receipt of only 6,825.144 MT (short by 18.556 MT, valued at US$7,100.16 or ₱186,743.20).
- Second Shipment and Judicial Proceedings
- On November 25, 1995, a second shipment of 3,300.000 MT was loaded on M/V Terna under a clean Berth Term Grain Bill of Lading. On January 25, 1996, respondent reported receipt of only 3,100.137 MT (short by 199.863 MT, valued at US$79,848.86 or ₱2,100,025.00).
- Respondent filed suit on December 3, 1996, against the unknown vessel owners, Inter-Asia Marine Transport, Inc. (the carrier’s local agent), and Asian Terminals, Inc. (ATI) as arrastre operator. The claim against Sea Dreama’s owner was later settled; remaining defendants answered, raised defenses (lack of cause, prescription, shipper’s weight unknown, inherent vice, late claim, due diligence, limits of carrier liability) and counterclaimed attorney’s fees.
- Trial Court and Appellate Decisions
- On May 10, 2001, the RTC of Manila held ATI, Inter-Asia and the vessel owner solidarily liable for ₱2,286,259.20 plus 10% attorney’s fees and costs; all counter- and cross-claims were dismissed.
- On November 27, 2006, the Court of Appeals affirmed the RTC decision except for deleting attorney’s fees against the carrier; ATI’s motion for reconsideration was denied on March 23, 2007.
- ATI petitioned the Supreme Court under Rule 45, raising questions of fact regarding actual shortage, bill of lading stipulations, inherent vice, proof of damages, carrier negligence, and ATI’s entitlement to its counterclaim.
Issues:
- Liability of ATI for Alleged Shortage
- Did respondent prove an actual shortage by establishing shipment weight at the port of origin versus arrival?
- Is the “shipper’s weight, quantity and quality unknown” clause in the bill of lading binding on respondent?
- Could any shortage be attributed to the inherent nature (e.g., moisture loss, consolidation) of soybean meal rather than carrier fault?
- Were the barge displacement (draught survey) methods reliable to determine loss?
- Did ATI exercise due diligence or commit negligence in unloading and custody?
- Entitlement to Counterclaim
- Is ATI entitled to recover its claimed attorney’s fees as counterclaim?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)