Title
Government of the Philippine Islands vs. Ynchausti and Co.
Case
G.R. No. 14191
Decision Date
Sep 29, 1919
The court ruled for the defendant, affirming that the plaintiff was bound by the bill of lading's terms and that tile damage resulted from the tiles' inherent nature, not negligence.
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Case Digest (G.R. No. 14191)

Facts:

  • The case involves the Government of the Philippine Islands (plaintiff) and Ynchausti & Company (defendant).
  • The plaintiff shipped roofing tiles from Manila to Iloilo on a vessel owned by the defendant.
  • Upon delivery, some tiles were found damaged, totaling approximately P200.
  • The plaintiff filed a complaint to recover the damages.
  • The lower court ruled against the plaintiff, finding no negligence on the defendant's part.
  • The defendant argued that the tiles were inherently fragile and were shipped without protective packing.
  • Loading and unloading were done manually, without mechanical assistance.
  • The tiles were shipped under a Government bill of lading with terms and conditions claimed to be binding on the plaintiff.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the terms and conditions on the bill of lading were binding on the plaintiff.
  • The Court held that there was no...(Unlock)

Ratio:

  • The Supreme Court reasoned that the plaintiff, by shipping goods under the bill of lading with the defendant's stamped terms, assented to those terms.
  • The plaintiff was aware of the implications of the Philippine Marine Regulations and could not claim ignorance.
  • The binding effect of the conditions arose from the contract formed through the bill of lading, not from the authority of the Insular Collector of Customs.
  • Under Article 361 of the Commercial Code, merchandise is transported at the risk of th...continue reading

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