Case Digest (G.R. No. 201193)
Facts:
In Caltex (Philippines), Inc. v. Sulpicio Lines, Inc. et al. (G.R. No. 131166, September 30, 1999), petitioner Caltex chartered the motor tanker MT Vector, owned and operated by Vector Shipping Corporation, under a voyage charter to transport 8,800 barrels of petroleum products from Limay, Bataan on December 19, 1987. On December 20, the passenger ship MV Doña Paz, owned and operated by Sulpicio Lines, Inc., departed Tacloban en route to Manila with 59 crew members and over 1,400 passengers. At about 10:30 p.m., the two vessels collided in the vicinity of Dumali Point, resulting in one of the worst maritime disasters in Philippine history with almost 4,000 casualties. A Board of Marine Inquiry found MT Vector and its operator at fault. The heirs of two unmanifested passengers, Teresita and Sotera Caéezal, filed a damage suit against Sulpicio Lines before the Regional Trial Court, which dismissed Sulpicio’s third-party complaint against Caltex and Vector Shipping. On appeal, theCase Digest (G.R. No. 201193)
Facts:
- Parties and Vessel Charter
- Caltex (Philippines), Inc. (petitioner) chartered MT Vector, a tramping motor tanker owned and operated by Vector Shipping Corporation, under a voyage charter for carriage of petroleum products.
- MT Vector departed Limay, Bataan on December 19, 1987 at about 8:00 p.m., laden with 8,800 barrels of Caltex gasoline, kerosene, diesel and crude oil.
- Passenger Vessel MV Doña Paz
- MV Doña Paz, a passenger and cargo vessel owned and operated by Sulpicio Lines, Inc., departed Tacloban on December 20, 1987 at about 6:30 a.m. bound for Manila.
- The Coast Guard Clearance listed 59 crew (master and officers) and 1,493 passengers; actual passengers exceeded 4,000, many unmanifested.
- Collision and Casualties
- On the night of December 20, 1987 at about 10:30 p.m., MT Vector and MV Doña Paz collided at sea near Dumali Point (between Marinduque and Oriental Mindoro).
- All but two of MT Vector’s crew and all but 24 of MV Doña Paz’s passengers and crew perished; the fire ignited by MT Vector’s cargo consumed both vessels.
- Investigations and Lower Courts
- Board of Marine Inquiry (BMI Case No. 653-87, March 22, 1988) found MT Vector, its operator Francisco Soriano and Vector Shipping Corporation at fault for the collision.
- On February 13, 1989, Teresita and Sotera Caáezal filed a complaint against Sulpicio Lines for damages arising from breach of contract of carriage; Sulpicio filed a third-party complaint against Vector Shipping, Soriano and Caltex alleging negligent charter.
- RTC Branch 8, Manila (September 15, 1992) dismissed Sulpicio’s third-party complaint against Caltex.
- Court of Appeals (April 15, 1997) modified RTC judgment, holding Caltex and Vector Shipping equally liable to indemnify Sulpicio Lines for damages awarded to the Caáezal heirs.
Issues:
- Liability of Charterer
- Whether a charterer under a voyage charter can be held liable for damages resulting from a collision involving the chartered vessel.
- Carrier Status and Charter Party
- Whether a voyage charter converts a common carrier into a private carrier, affecting the allocation of responsibility for seaworthiness and third-party claims.
- Negligence and Duty of Diligence
- Whether Caltex, as charterer and shipper, owed a duty to inspect the vessel’s seaworthiness and documents and whether its alleged failure constitutes actionable negligence under the Civil Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)