Case Digest (G.R. No. L-15654)
Facts:
The case involves Delgado Brothers, Inc. as the petitioner and Richard A. Kleeper as the respondent, wherein Kleeper filed an action in the Court of First Instance of Manila to claim damages amounting to P6,729.50 resulting from damage to his goods while being unloaded from the S.S. President Cleveland, a ship owned by American President Lines, Ltd. Kleeper's goods were housed in a lift van that fell to the ground due to negligence during unloading on February 22, 1955. Upon review, it was found that Kleeper shipped the lift van from Yokohama, Japan, under bill of lading No. 82, packing personal and household effects. Following the incident, a survey assessed the damages caused to the goods. On November 5, 1957, the trial court ruled in favor of Kleeper, ordering the shipping company to pay P6,729.50 in damages, an additional P500.00 for sentimental value, and P1,000.00 for attorney's fees while also indicating that once the judgment was satisfied, Delgado Brothers, Inc
...Case Digest (G.R. No. L-15654)
Facts:
- Background of the Case
- Richard A. Kleeper, the respondent, filed an action to recover damages for goods shipped on board S.S. President Cleveland.
- The shipment, consisting of a lift van containing personal and household effects, departed from Yokohama, Japan on February 17, 1955, under bill of lading No. 82.
- The ship arrived in Manila on February 22, 1955.
- Incident and Damages
- While being unloaded at the pier, the lift van was handled by a gantry crane operated by Delgado Brothers, Inc.
- The lift van fell during unloading, causing its contents to spill and suffer damages including breakage, denting, and smashing of the goods.
- A survey determined that the total amount of damages amounted to P6,729.50, with an additional P2,000.00 claimed for sentimental value and P1,000.00 for attorney’s fees.
- Trial Court’s Decision
- On November 5, 1957, the trial court ordered the shipping company (American President Lines, Ltd.) to pay Kleeper P6,729.50 for the value of the damaged goods, along with P500.00 as sentimental value and P1,000.00 as attorney’s fees, with legal interest from the filing of the complaint.
- The trial court also ordered that, once the judgment was satisfied, co-defendant Delgado Brothers, Inc. reimburse the shipping company the same amounts.
- Appeal and Contentions Raised
- Both defendants (the shipping company and Delgado Brothers, Inc.) appealed the trial court’s decision.
- The Court of Appeals affirmed the judgment, holding that Delgado Brothers, Inc. could not disclaim liability, particularly for the negligence of its crane operator.
- Delgado Brothers, Inc. filed a petition for review, arguing that a contract (Exhibit 1-Delgado) expressly relieved it from liability related to the operation of its gantry crane.
- The Controversial Contract (Exhibit 1-Delgado)
- The contract requested the use of one gantry crane on hatch No. 2 of the S.S. President Cleveland for the unloading operation, dated February 22, 1955.
- It stated that the shipping company assumed full responsibility and liability for any damages arising from the use of the crane.
- It explicitly provided that the shipping company would not hold Delgado Brothers, Inc. liable in any way and agreed to pay the corresponding charges for the service.
- Delgado Brothers, Inc. contended that this stipulation should exculpate it from liability, including for negligence on the part of its crane operator.
Issues:
- Primary Issue
- Whether Delgado Brothers, Inc. (petitioner) may be held liable for the damage to Kleeper’s goods subsidiarily to the liability of its co-defendant, American President Lines, Ltd., given the contractual stipulation purportedly exempting it.
- Contract Interpretation Issue
- Whether the language in Exhibit 1-Delgado is sufficiently clear and unambiguous in exempting Delgado Brothers, Inc. from liability, including for acts of negligence committed by its employee (the crane operator).
- How the two-part clause, which both grants the shipping company responsibility for the use of the crane and simultaneously absolves Delgado Brothers, Inc. of liability, should be interpreted under prevailing legal doctrines.
- Contextual Legal Provisions
- The applicability and interpretation of provisions under the New Civil Code (Articles 1753 and 1766) regarding common carrier liability in cases not regulated by the Code.
- The relevance of the Carriage of Goods by Sea Act and its limitation clause in relation to the damages claimed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)