Title
Caltex , Inc. vs. Manila Port Service
Case
G.R. No. L-24591
Decision Date
Sep 29, 1967
Caltex sued Manila Port Service for undelivered pig tin ingots; SC ruled provisional claim valid, 15-day period starts upon discovery, awarded attorney's fees.
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Case Digest (G.R. No. L-24591)

Facts:

1. Parties Involved:

  • Plaintiff and Appellee: Caltex (Philippines) Inc.
  • Defendants and Appellants: Manila Port Service and Manila Railroad Company.

2. Nature of the Case:

  • The case involves a claim for the value of undelivered goods (222 ingots of pig tin) shipped to Caltex (Philippines) Inc. by the defendants, who acted as arrastre operators at the Port of Manila.

3. Shipment Details:

  • The shipment of 222 ingots of pig tin arrived at the Port of Manila on January 9, 1961, aboard the vessel "SS Aso Maru."
  • The shipment was discharged into the custody of the defendants on the same day.

4. Delivery and Claims:

  • Only 16 ingots were delivered to Caltex.
  • Caltex filed a provisional claim on January 25, 1961, followed by a formal claim on August 11, 1961, for the value of the undelivered ingots (P2,311.66), plus attorney's fees and costs.

5. Legal Proceedings:

  • The Municipal Court of Manila initially dismissed the case, but the Court of First Instance of Manila ruled in favor of Caltex.
  • The defendants appealed, challenging the sufficiency of the provisional claim and its timeliness under the Management Contract.

6. Management Contract Provisions:

  • The contract required claims to be filed within 15 days from the date of discharge of the last package from the carrying vessel.
  • It also limited the liability of the arrastre operators to P500 per package unless the value was specified and corresponding arrastre charges were paid.

Issue:

  1. Sufficiency of the Provisional Claim:

    • Whether the provisional claim filed by Caltex was sufficient under the Management Contract, particularly regarding the statement of the value of the missing goods.
  2. Timeliness of the Provisional Claim:

    • Whether the provisional claim was filed within the 15-day period prescribed by the Management Contract, starting from the date of discharge of the last package.
  3. Award of Attorney's Fees:

    • Whether the award of attorney's fees to Caltex was justified.

Ruling:

  1. Sufficiency of the Provisional Claim:

    • The Supreme Court held that the provisional claim was sufficient. The law does not require the value of the goods to be stated in the provisional claim, as long as the claimant signifies the intent to demand payment of such value.
  2. Timeliness of the Provisional Claim:

    • The Court ruled that the 15-day period should be computed from the date the claimant learns of the loss, damage, or misdelivery, or from the date such information could have been reasonably obtained. Since there was no evidence on when Caltex learned of the loss, the defendants' defense based on timeliness could not be sustained.
  3. Award of Attorney's Fees:

    • The Court affirmed the award of attorney's fees, considering the circumstances of the case, the appeal reaching the Supreme Court, and the defendants' reliance on technicalities to deny legitimate claims.

Ratio:

  1. Purpose of Provisional Claims:

    • The primary purpose of a provisional claim is to provide the arrastre operator with a reasonable opportunity to verify the claim while the facts are still fresh and documents are available. The value of the goods need not be specified in the provisional claim.
  2. Computation of the 15-Day Period:

    • The 15-day period for filing a provisional claim should be computed from the date the claimant learns of the loss or could have reasonably discovered it, not necessarily from the date of discharge of the goods.
  3. Attorney's Fees:

    • Attorney's fees may be awarded when the appeal reaches the Supreme Court, especially when the defendants rely on technicalities to deny claims, thereby necessitating prolonged litigation.

Conclusion:

The Supreme Court affirmed the decision of the Court of First Instance of Manila, ruling in favor of Caltex (Philippines) Inc. and ordering the defendants to pay the value of the undelivered ingots, attorney's fees, and costs. The Court emphasized that technicalities should not undermine substantive rights, and the purpose of provisional claims is to facilitate timely verification, not to impose undue burdens on claimants.


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