G.R. No. 240984 - Harbour Centre Port Terminal, Inc. vs. La Filipina Uygongco Corp.

On November 19, 2004, Harbour Centre Port Terminal, Inc. (HCPTI) and La Filipina Uygongco Corp. (LFUC) – together with its sister company, Philippine Foremost Milling Corp. (PFMC) – entered into a Memorandum of Agreement (MOA).
The MOA granted LFUC and PFMC priority berthing rights at the Manila Harbour Centre, subject to certain conditions such as the submission of a written Final Advice of Arrival (FAA) and, where applicable, the notification of the vessel’s Expected Time of Arrival (ETA).

In 2008, relations between HCPTI and the respondents became strained.
On August 29, 2008, HCPTI sent a letter demanding payment of accountabilities amounting to over P362 million for rental, overhauling, wharfage fees, and additional charges.
Respondents LFUC and PFMC countered that HCPTI had failed to provide the contracted priority berthing and proper maintenance (i.e., dredging) of the navigational channel and berthing area.

Respondents filed a Complaint for Compliance with Maritime Law and other causes (Civil Case No. 08-119957) against HCPTI, which led to the issuance of a 72-hour restraining order and later a 20-day Temporary Restraining Order (TRO) on September 11, 2008.
A Writ of Preliminary Injunction (WPI) was subsequently issued by RTC Branch 24 on September 25, 2008, enjoining HCPTI from preventing respondents’ access to its rail lines, unloaders, and use of port facilities.
Despite the injunction, from March 9, 2009, to June 28, 2009, around 24 barges and tugboats under respondents’ charter experienced delays or were denied access to the berthing area, contravening the MOA and WPI.
Specific incidents included instances where barges, though ready for berthing and having submitted required documentations (e.g., the PPA Application for Berth/Anchorage and HCPTI Commitment Sheet), were either not allowed access or were forced to vacate before unloading was completed.

In response to the delays and denial of priority berthing rights, respondents filed a Petition for Indirect Contempt on August 13, 2009, against HCPTI and its officers – namely, Michael L. Romero, Edwin L. Jeremillo, and Henry Rophen V. Virola – alleging willful violation of the WPI and the MOA.
HCPTI, in its Answer, denied the allegations, arguing that:

Respondents failed to adhere to the MOA’s requirements by not submitting the written FAA.
Some vessels either did not apply for berthing or were not serviced during the relevant period (March 19, 2010 to June 28, 2010).
The charge of indirect contempt is inherently criminal, thus necessitating the rules of evidence applicable in criminal proceedings.

The Regional Trial Court (RTC) of Manila, Branch 42 rendered a decision on February 2, 2015, dismissing the petition for indirect contempt on the ground that respondents had not complied with the MOA by failing to submit a written FAA and ETA details.
The RTC’s denial of respondents’ motion for reconsideration was issued on October 8, 2015.
The Court of Appeals (CA) reversed and set aside the RTC decision in its July 13, 2017 ruling, finding HCPTI and its officers liable for indirect contempt by violating the WPI and the MOA.
The CA further classified the petition for indirect contempt as civil in nature rather than criminal, a determination upheld when petitions for reconsideration were denied in a Resolution dated July 24, 2018.
Petitioners (HCPTI and Romero) then sought review on certiorari, consolidating their appeals (G.R. Nos. 240984 and 241120), challenging both the finding of liability and the characterization of the proceeding as civil.

Whether the CA erred in holding the petitioners liable for indirect contempt by finding that they willfully violated the WPI and the MOA.
Whether the CA correctly determined that the petition for indirect contempt is civil in nature, despite the punitive elements sought by the respondents.