G.R. No. 86220 - People vs. Ciobal y Pabrua

In April 1980, private respondent Ramon Miranda purchased four special cabin tickets (ticket numbers 74411, 74412, 74413, and 74414) from Negros Navigation Co., Inc. for his wife, daughter, son, and niece.
The tickets were for Voyage No. 457-A of the M/V Don Juan, scheduled to leave Manila on April 22, 1980, for Bacolod City where a family reunion was to be attended.

The M/V Don Juan sailed from the North Harbor, Manila on schedule.
On the evening of April 22, 1980, at approximately 10:30 p.m., the vessel collided in the Tablas Strait, Mindoro, with the oil tanker M/T Tacloban City, owned by PNOC and PNOC/STC.
Due to the collision, the M/V Don Juan sank rapidly, leading to the death of several passengers, including the relatives of the private respondents.

Private respondent Ramon Miranda testified that he personally accompanied his family and niece onto the vessel that day and remained with them until departure.
The passenger manifest, which was part of the evidence, listed the corresponding ticket numbers and the names of Ardita Miranda, her children, and Elfreda de la Victoria, corroborating their presence on board.
Despite the absence of the victims' bodies among the recovered wreckage, evidence suggested that this was consistent with the fate of many passengers in a mass maritime disaster.

The petitioner (Negros Navigation Co., Inc.) conceded that the tickets were sold and that the vessel departed as scheduled but denied that the alleged victims boarded the ship, basing its argument solely on the fact that their bodies were never recovered.
The petitioner asserted that the collision was due exclusively to the negligence of the crew of the oil tanker, and further maintained that the vessel was seaworthy, manned by a competent crew, and that it had performed its duties with the expected level of ordinary diligence.

On January 20, 1986, petitioner Negros Navigation Co., Inc. and PNOC entered into a compromise agreement wherein petitioner assumed full responsibility for all claims arising from the collision, releasing PNOC and PNOC/STC from liability. Private respondents, however, did not join this agreement.
The Regional Trial Court rendered a judgment on February 21, 1991, awarding damages to the private respondents for actual, compensatory (including loss of earning capacity and wrongful death), moral, exemplary damages, and attorney’s fees.
On appeal, the Court of Appeals affirmed the trial court’s decision with modifications, including adjustments in the amounts awarded for actual damages and compensatory damages.

Testimonies, including that of private respondent Ramon Miranda and survivor Edgardo Ramirez, confirmed the presence of the victims on board. Ramirez’s detailed account of being with the victims until the collision further corroborated this fact.
The lower courts, and eventually the Supreme Court, relied on findings from the earlier Mecenas case where it was established that the crew of the M/V Don Juan (including practices such as playing mahjong during the voyage) were grossly negligent.
Evidence showed that the vessel was overloaded and that preventive measures, such as early corrective action upon detecting the opposing vessel via radar, were not taken.

Whether the members of private respondent Ramon Miranda’s family (as well as the niece) were indeed passengers on the M/V Don Juan as they had purchased tickets.
Whether the lack of recovery of the bodies negates the testimony regarding their presence on the vessel.

Whether the ruling in the Mecenas v. Intermediate Appellate Court case, which found the crew of the Don Juan grossly negligent, is binding and applicable to the present case.
Whether the evidence and conclusions drawn in the Mecenas case can be directly applied despite differences in parties and specific circumstances.

Whether the total loss of the M/V Don Juan extinguished Negros Navigation’s liability for the damages incurred by the private respondents.
Whether a shipowner may still be held liable for injuries and wrongful death resulting from negligence, even if the vessel is lost in its entirety.

Whether the damages awarded by the lower court and modified by the Court of Appeals, including actual, compensatory (for loss of earning capacity and wrongful death), moral, exemplary damages, and attorney’s fees, are excessive and/or unreasonable.
Whether the formula in computing loss of earning capacity (including the deduction for living expenses) was appropriately applied, especially in the context of Mrs. Miranda’s expected earnings.