Case Digest (G.R. No. 97412) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 97412 decided on July 12, 1994 under the 1987 Constitution, Mercantile Insurance Company, Inc., as subrogee of the consignee, sued Eastern Shipping Lines, Inc. (common carrier), Metro Port Service, Inc. (arrastre operator) and Allied Brokerage Corporation (customs broker) before the Court of First Instance of Manila for P19,032.95, representing payment under Marine Insurance Policy No. 81/01177 for damage to two fiber drums of riboflavin shipped from Yokohama on December 4, 1981 under Bill of Lading No. YMA-8. Upon arrival in Manila on December 12, 1981, Metro Port Service received the drums and noted one drum “in bad order.” On January 7, 1982, Allied Brokerage took delivery and found one drum opened and leaking 15 kgs of contents; deliveries on January 8 and 14 revealed adulterated content in one drum. Having paid the consignee under the insurance coverage, Mercantile Insurance was subrogated to its rights and presented claims against all three defendants, which we Case Digest (G.R. No. 97412) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Shipment and Insurance
- On December 4, 1981, two fiber drums of riboflavin were shipped from Yokohama, Japan, for carriage by vessel SS EASTERN COMET under Bill of Lading No. YMA-8, owned by Eastern Shipping Lines, Inc.
- The shipment was insured under Marine Insurance Policy No. 81/01177 for P36,382,466.38; Mercantile Insurance Company, Inc. paid the consignee and became subrogee.
- Handling and Damage Discoveries
- December 12, 1981: Shipment discharged at Manila and turned over to Metro Port Service, Inc. Metro Port noted one drum in “bad order.”
- January 7, 1982: Allied Brokerage Corporation received the drums—one was found opened without seal with 15 kgs of spillages.
- January 8 & 14, 1982: Delivery to consignee’s warehouse revealed one drum with adulterated/fake contents; consignee’s losses amounted to P19,032.95.
- Trial Court Proceedings
- Mercantile Insurance, as subrogee, sued Eastern Shipping (carrier), Metro Port (arrastre operator), and Allied Brokerage (customs broker) for negligence in handling goods.
- Defendants denied liability, attributing damage to prior custody or packing defects.
- Trial court found damage occurred in successive custody of all three, held them jointly and severally liable for P19,032.95, plus 12% interest per annum from October 1, 1982, P3,000 attorneys’ fees, and costs. Allied Brokerage’s counterclaims were dismissed.
- Court of Appeals and Supreme Court Filings
- The Court of Appeals affirmed the trial court in toto.
- Eastern Shipping petitioned the Supreme Court, challenging solidary liability and the computation and rate of legal interest.
Issues:
- Whether the carrier, arrastre operator, and customs broker are solidarily liable for the damage claim.
- Whether legal interest on the award runs from the filing of the complaint or from the date of the trial court’s decision.
- Whether the applicable rate of legal interest is 12% per annum or 6% per annum.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)