Case Digest (G.R. No. 199455) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Federal Express Corporation v. Luwalhati R. Antonino and Eliza Bettina Ricasa Antonino (G.R. No. 199455, June 27, 2018), the Antonino sisters owned Unit 22-A of Allegro Condominium in New York. Common charges and real estate taxes for July–November 2003 amounting to US$21,362.16 became due. On December 15, 2003, they shipped Citibank checks totalling US$29,345.53 to their New York representative, Veronica Z. Sison, via FedEx (Account No. x2546-4948-1, Tracking No. 8442 4588 4268), with instructions to deliver them to Maxwell-Kates, Inc. and the New York County Department of Finance. Sison never received the package; FedEx records indicated delivery to a neighbor under an alphanumeric code without a signed receipt. The Unit was foreclosed for nonpayment. After sending a demand letter on March 14, 2004 and receiving no satisfaction, the Antoninos filed a complaint on April 5, 2004, for damages due to non-delivery. FedEx counterclaimed, invoking respondents’ purported failure to Case Digest (G.R. No. 199455) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Case History
- Petitioners: Federal Express Corporation (FedEx), a common carrier.
- Respondents: Luwalhati R. Antonino and Eliza Bettina Ricasa Antonino, condominium owners in New York.
- Procedural posture: Respondents obtained judgment in the Regional Trial Court (RTC) for damages due to non‐delivery of a package. The Court of Appeals (CA) affirmed. FedEx filed a Petition for Review on Certiorari under Rule 45 to the Supreme Court, challenging CA’s August 31, 2011 Decision and November 21, 2011 Resolution.
- Underlying Shipment and Loss
- In December 2003, respondents needed to pay US$9,742.81 in common charges (July–November 2003) and US$11,619.35 in real estate taxes for their New York condominium.
- On December 15, 2003, respondents shipped Citibank checks totaling US$29,345.53 via FedEx (Account No. x2546-4948-1; Tracking No. 8442 4588 4268) addressed to their New York-based agent, Veronica Z. Sison, for onward payment to Maxwell-Kates, Inc. and the New York County Department of Finance.
- Sison never received the package. Upon inquiry on February 9, 2004, FedEx claimed delivery to a neighbor without a signed receipt. No named recipient was identified.
- Demand, Trial Court Decision, and Appellate Rulings
- Respondents sent a written demand on March 14, 2004. FedEx refused, citing respondents’ failure to file a claim within 45 days and alleging prohibited shipment of negotiable instruments misdeclared as documents.
- On April 5, 2004, respondents filed suit for damages. RTC Branch 217, Quezon City, ruled in their favor (May 8, 2008), awarding P200,000 moral damages, P100,000 exemplary damages, and P150,000 attorney’s fees; counterclaim dismissed.
- CA denied FedEx’s appeal (August 31, 2011) and its motion for reconsideration (November 21, 2011), affirming that (a) substantial compliance with the 45-day notice period was established, (b) checks are not “money” or legal tender under the Air Waybill prohibition, and (c) ambiguities in an adhesive contract are construed against the carrier.
Issues:
- Condition Precedent
- Whether respondents complied with the Air Waybill condition requiring a formal written claim within 45 days of acceptance.
- Carrier Liability and Duty of Care
- Whether FedEx exercised the extraordinary diligence mandated of common carriers from receipt until delivery to the authorized consignee.
- Prohibition Against Shipment of Money
- Whether checks constitute “money (including … negotiable instruments equivalent to cash)” prohibited under FedEx’s Air Waybill, thereby absolving FedEx of liability.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)