Case Digest (G.R. No. L-22684) Core Legal Reasoning Model
Facts:
In the case of The Government of the Philippine Islands vs. Philippine Steamship Co., Inc. and Fernandez Hermanos, G.R. No. 18957, decided on January 16, 1923, the Government sought to recover the sum of P14,648.25, representing the value of 911 sacks of rice that were lost at sea due to a collision between the steamer Antipolo, owned by the defendant Philippine Steamship Co., Inc., and the vessel Isabel, which was transporting the rice. The collision occurred on February 11, 1920, near Manila Bay. The Isabel set sail from Manila around 10 PM for Balayan, Batangas, carrying the rice consigned to various destinations in the south.
A few hours into its journey, the crew of the Isabel spotted the Antipolo, which was under way toward Manila. Both vessels were initially approximately 1.5 to 2 miles apart and moving at speeds of about 6 miles per hour toward each other. The mate on the Antipolo, who was at the helm, reacted to their dangerously close proximity by steering the vessel
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Case Digest (G.R. No. L-22684) Expanded Legal Reasoning Model
Facts:
1. Incident Overview
On February 10, 1920, the coastwise vessel Isabel, equipped with motor and sails, departed Manila for Balayan, Batangas, carrying 911 sacks of rice owned by the Government of the Philippine Islands. The rice was consigned to destinations in the south.
2. Collision Details
At approximately 2:00 AM on February 11, 1920, near the San Nicolas Light at the entrance of Manila Bay, the Isabel and the Antipolo, another coastwise vessel owned by the Philippine Steamship Co., Inc., collided. Both vessels were traveling at about 6 miles per hour and were approximately 1.5 to 2 miles apart when they first sighted each other.
3. Actions Leading to Collision
- The mate of the *Antipolo*, upon realizing the danger, correctly turned the helm hard to starboard.
- The mate of the *Isabel*, however, panicked and turned the helm hard to port, causing the vessel to veer into the path of the *Antipolo*.
- Despite the *Antipolo* stopping its engines, the *Isabel* continued at full speed, resulting in a collision near the bows. The *Isabel* sank, resulting in the total loss of the vessel and its cargo, though the crew was rescued.
4. Negligence Findings
- The *Antipolo* was negligent for allowing the vessel to approach the *Isabel* too closely without giving it a wide berth.
- The *Isabel* was negligent for the incorrect handling of the vessel at the critical moment, likely due to the mate's exhaustion from continuous duty.
Issues:
- Whether both vessels were at fault for the collision.
- Whether the Philippine Steamship Co., Inc., as the owner of the *Antipolo*, is liable for the loss of the rice owned by the Government of the Philippine Islands.
- Whether Article 827 of the Code of Commerce applies to the case, particularly in determining liability when both vessels are at fault.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)