Facts:

• The case involves Oriental Assurance Corporation (petitioner) against Manuel Ong (doing business as Western Pacific Transport Services) and Asian Terminals, Inc. (respondents).
• JEA Steel Industries, Inc. imported 72 aluminum-zinc-alloy-coated steel sheets from South Korea, transported by the vessel M/V Dooyang Glory.
• Upon arrival at Manila South Harbor on June 10, 2002, the coils were discharged and stored at Pier 9 under Asian Terminals' custody.
• The coils were loaded onto trucks owned by Ong and delivered to JEA Steel's plant in Trece Martires, Cavite, on June 14 and June 17, 2002.
• Upon delivery, 11 coils were found damaged (dented or deformed).
• JEA Steel filed a claim with Oriental Assurance Corporation under Marine Insurance Policy No. OAC/M-12292 for the damaged coils, receiving P521,530.16.
• Oriental sought indemnity from Ong and Asian Terminals, who refused to pay.
• Oriental filed a complaint on May 19, 2003, in the Regional Trial Court of Manila for the sum of money against the respondents.
• Ong claimed the coils were damaged before loading, while Asian Terminals asserted it exercised due diligence and that Oriental's claim was barred due to a failure to file a notice of claim within the 15-day period.
• The Regional Trial Court dismissed the complaint on August 9, 2006, citing insufficient evidence of the respondents' liability.
• Oriental's motion for reconsideration was denied, and the Court of Appeals upheld the dismissal, ruling that Oriental's claim had prescribed.
• Oriental subsequently filed a petition for review before the Supreme Court.

Issue:

• (Unlock)

Ruling:

• The Court of Appeals did not err in addressing the issue of prescription.
• The claim against Asian Terminals is not barred by prescription; the consignee's claim letter constitutes substantial compliance with the time limitation for filing claims....(Unlock)

Ratio:

• The Supreme Court held that the Court of Appeals acted within its authority to address the issue of prescription, as it was closely related to Asian Terminals' liability and had been raised in the lower court.
• The provisions of the Management Contract and the Gate Pass are binding on Oriental as the insurer-subrogee of the consignee, even though Oriental was not a party to these documents.
• The 15-day prescriptive period for filing claims is a condition precedent to the accrual of a cause of action against the arrastre operator.
• The consignee's claim letter, ...continue reading