Title
Macam vs. Court of Appeals
Case
G.R. No. 125524
Decision Date
Aug 25, 1999
A businessman files a collection case against a shipping company and a buyer after a shipment of fruits was mistakenly delivered without the required documents, but the court rules in favor of the defendants, stating that the release of the goods was proper based on the buyer's request and the perishable nature of the goods.
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Case Digest (G.R. No. 125524)

Facts:

  • Petitioner Benito Macam, operating under Ben-Mac Enterprises, shipped 3,500 boxes of watermelons and 1,611 boxes of fresh mangoes to Great Prospect Company (GPC) in Hong Kong.
  • Shipment was documented under Bills of Lading Nos. HKG 99012 and HKG 99013.
  • The consignee was the National Bank of Pakistan, Hong Kong (PAKISTAN BANK), with GPC as the notify party.
  • Upon arrival in Hong Kong, the shipment was delivered by respondent Wallem Philippines Shipping, Inc. (WALLEM) directly to GPC without the required bill of lading being surrendered.
  • GPC failed to pay PAKISTAN BANK, which then refused to pay the petitioner through Solidbank.
  • Petitioner sought to recover the amount from WALLEM but was refused.
  • Petitioner filed a collection case before the Regional Trial Court of Manila.
  • The trial court ruled in favor of the petitioner, ordering respondents to pay the value of the shipment plus legal interest, attorney's fees, and costs.
  • The Court of Appeals reversed this decision, dismissing the complaint and the counterclaims.
  • The Supreme Court ultimately denied the petition, affirming the Court of Appeals' decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the respondents are not liable to the petitioner for releasing the goods to GPC without the bills of lading or bank guarantee.
  • The petition was denied, and the decision of...(Unlock)

Ratio:

  • The Supreme Court emphasized that the extraordinary responsibility of common carriers lasts until the actual or constructive delivery of the cargoes to the consignee or to the person who has a right to receive them.
  • GPC, as the buyer/importer, had the right to receive the goods.
  • The Court noted that the petitioner had a practice of requesting immediate release of perishable goods without the presentation of bills of lad...continue reading

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