Title
Manila Railroad Co. vs. La Compania Trasatlantica
Case
G.R. No. 11318
Decision Date
Oct 26, 1918
A steamship company hired an independent contractor to unload heavy boilers; negligence during the operation caused damage. The steamship company was liable to the cargo owner, while the contractor was liable to the steamship company but not directly to the cargo owner due to lack of privity.

Case Digest (G.R. No. 11318)
Expanded Legal Reasoning Model

Facts:

  • Arrival of locomotive boilers and engagement of lifting services
    • March 1914: Steamship Alicante (Compania Trasatlantica) arrives at Manila carrying two locomotive boilers owned by The Manila Railroad Company; ship’s own gear is inadequate for heavy cargo.
    • Steamship Company engages Atlantic, Gulf & Pacific Co. to bring its floating crane alongside, lift the boilers, and transfer them to a barge.
  • Lifting operations and accidents
    • First hoisting: sling placed near boiler’s mid-length, boiler raised nearly horizontal, one end caught under hatch edge, added strain (~15 tons) breaks sling cable, boiler falls into ship’s hold.
    • Second hoisting: sling repositioned near an end, shock from first accident weakened derrick-boom bolt, bolt breaks, boiler falls again; after repairs, boiler discharged but badly damaged.
  • Damage and litigation
    • Boiler re-shipped to England for reconstruction, then returned; Railroad Company’s proven loss (repairs, expenses, loss of use) = P 22,343.29.
    • Railroad Co. sues Steamship Co.; Steamship Co. impleads Atlantic Co. as codefendant, contending independent-contractor liability. Trial court finds gross negligence of Atlantic Co.’s foreman (Leyden), absolves Steamship Co., holds Atlantic Co. liable; both appeal.

Issues:

  • Is the Steamship Company liable to the Railroad Company for delivering the boiler in a damaged condition under their contract of carriage?
  • Is the Atlantic Company liable to indemnify the Steamship Company under their contract for lifting services, despite an alleged exemption clause?
  • Can the Atlantic Company be held directly liable to the Railroad Company in absence of contractual privity?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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