Case Digest (G.R. No. L-17050)
Facts:
The case involves Atlantic Mutual Insurance Company as the plaintiff and appellee, and Macondray & Co., Inc., along with the Manila Port Service and/or Manila Railroad Company as the defendants and appellants. The events leading to the case began on April 20, 1956, when the American Bible Society of New York shipped 312 cartons of Holy Scriptures aboard the "S.S. Leoville," operated by Barber Steamship Lines, Inc. The shipment was consigned to the Philippine Agency, Bible House, Manila, and was insured by the plaintiff. The cargo was discharged at the Port of Manila between May 29 and June 2, 1956. According to the good order tally sheets, 309 cases were unloaded in good condition, while three cases discharged on June 1, 1956, were noted as being in bad order. However, marine surveyors later determined that the contents of these three cases were generally in good condition, with only minor damages to the covers of two copies of the Holy Scriptures. On June 6, 19...
Case Digest (G.R. No. L-17050)
Facts:
Shipment Details:
- On April 20, 1956, the American Bible Society of New York shipped 312 cartons and cases of Holy Scriptures to Manila via the "S.S. Leoville" of the Barber Steamship Lines, Inc.
- The shipment was consigned to the Philippine Agency, Bible House, Manila, and insured by the plaintiff, Atlantic Mutual Insurance Company.
Discharge and Inspection:
- From May 29 to June 2, 1956, the shipment was unloaded at the Port of Manila by the Manila Port Service (a subsidiary of the Manila Railroad Company).
- According to the good order tally sheets, 309 cases were discharged "complete and in good order."
- Three cases were discharged on June 1, 1956, in bad order, but marine surveyors found their contents in good condition, except for minor damage to two copies of Holy Scriptures.
Further Damage Discovered:
- On June 6, 1956, the consignee requested an inspection of 162 cases, which appeared in good condition but showed signs of having been wet.
- On June 9, 1956, another inspection revealed that five cases and their contents were wet with fresh water and damaged.
- The total damage was assessed at P532.86.
Responsibility:
- The Manila Port Service's responsibility over the damaged goods began on the dates they were unloaded into its custody (May 29 to June 2, 1956).
Legal Proceedings:
- The plaintiff, having paid the loss, filed a subrogation claim against Macondray & Co., Inc. (the agent of the carrier) and the Manila Port Service.
- The lower court ruled in favor of the plaintiff, holding the Manila Port Service and Manila Railroad Company liable for the damage.
Issue:
The primary issue is whether the damage to the shipment occurred while the goods were still on board the vessel (making the carrier liable) or after they were discharged into the custody of the Manila Port Service (making the latter liable).
Ruling:
The Supreme Court affirmed the lower court's decision, holding the Manila Port Service and Manila Railroad Company liable for the damage. The Court ruled that since the goods were received by the Manila Port Service in good order and later found damaged while in its custody, the presumption of fault under Article 265 of the Civil Code applies. The appellants failed to rebut this presumption.
Ratio:
- (Unlock)