Case Digest (G.R. No. L-23879)
Facts:
The case involves the Domestic Insurance Company of the Philippines (plaintiff-appellant) against Barber Line, Macondray & Co., Inc., and/or the Republic of the Philippines (defendants-appellees). The events leading to the case began on May 17, 1963, when the SS Queensville loaded a consignment of cargo in New York, U.S.A., destined for the Centennial Commercial Corporation in Manila. Among the cargo were three cartons of shears, for which Barber Line issued a Bill of Lading. The vessel arrived in Manila on June 24, 1963, and subsequently discharged its cargo into the custody of the arrastre operator, which was under the Bureau of Customs. The consignee, Centennial Commercial Corporation, completed all necessary shipping documents through the defendants and the Bureau of Customs. However, due to alleged negligence on the part of the defendants, certain items from the shipment were not delivered, resulting in a lo...
Case Digest (G.R. No. L-23879)
Facts:
Parties Involved
- Plaintiff-Appellant: Domestic Insurance Company of the Philippines (as insurer-subrogee of the cargo).
- Defendants-Appellees: Barber Line, Macondray & Co., Inc., and/or the Republic of the Philippines (as operator of the arrastre service through the Bureau of Customs).
Background of the Case
- On or about May 17, 1963, the SS Queensville took on board a consignment of cargo in New York, U.S.A., for shipment to Centennial Commercial Corporation in Manila. This included three cartons of shears, for which Barber Line issued a Bill of Lading.
- The vessel arrived in Manila on June 24, 1963, and discharged the cargo into the custody of the arrastre operator (Bureau of Customs).
- The consignee cleared all shipping documents through the defendants and the Bureau of Customs.
Allegations
- The plaintiff alleged that due to the negligence of the defendants, the shipment sustained losses amounting to P8,800.92 for certain undelivered items.
- The Republic of the Philippines, as the operator of the arrastre service, was named as an alternative defendant in the suit for money filed by the plaintiff.
Procedural History
- The Republic of the Philippines filed a motion to dismiss the case against it, citing state immunity from suit without its consent.
- The lower court granted the motion and dismissed the case as to the Republic. The plaintiff appealed this decision.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- The operation of the arrastre service by the Republic of the Philippines is an incident of its prime governmental function of assessing and collecting revenues, tariffs, and customs duties from importations.
- The doctrine of state immunity applies in this case, as the Republic was acting in its sovereign capacity. Without its consent, the Republic cannot be sued.
- The Court reiterated its rulings in similar cases, such as Mobil Philippines Exploration v. Customs Arrastre Service, Insurance Co. of North America v. Republic of the Philippines, and Manila Electric Co. v. Customs Arrastre Service, where it consistently upheld the principle of state immunity in the context of arrastre operations.
Conclusion:
The Supreme Court affirmed the dismissal of the case against the Republic of the Philippines, holding that the state is immune from suit in this context. No costs were awarded.