Case Digest (G.R. No. 101503) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Planters Products, Inc. v. Court of Appeals et al. (G.R. No. 101503, September 15, 1993), Planters Products, Inc. (PPI) purchased 9,329.7069 metric tons of Urea 46% fertilizer from Mitsubishi International Corporation (MITSUBISHI) on June 16, 1974. The cargo was shipped in bulk aboard M/V “Sun Plum,” owned by Kyosei Kisen Kabushiki Kaisha (KKKK), under Bill of Lading No. KP-1. Prior to departure, on May 17, 1974 in Tokyo, Mitsubishi (as charterer) and KKKK (as shipowner) executed a time charter-party under the “GENCON” form with riders (pars. 16–40) and addenda Nos. 1–4. Pursuant to par. 16, four holds were inspected by the charterer’s representative and pronounced fit, and M/V “Sun Plum” was presented clean for bulk cargo. The fertilizer was loaded by stevedores hired by the shipper; the steel hatches were then closed, sealed with three layers of tarpaulin tied with steel bonds, and remained so in transit. Upon arrival at Poro Point, La Union, on July 3, 1974, PPI unloaded t Case Digest (G.R. No. 101503) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Contractual Arrangements
- Planters Products, Inc. (PPI) purchased 9,329.7069 M/T of Urea 46% fertilizer from Mitsubishi International Corp. (MITSUBISHI) in New York, shipped aboard M/V “Sun Plum” owned by Kyosei Kisen Kabushiki Kaisha (KKKK).
- Time charter-party executed 17 May 1974 in Tokyo between MITSUBISHI (charterer/shipper) and KKKK (shipowner) under the “GENCON” form with Riders (pars. 16–40) and four Addenda (18, 20, 21, 27 May 1974).
- Loading, Voyage, and Arrival
- Four holds were inspected by charterer’s appointee, certified clean and dry pursuant to cl. 16. Urea was loaded in bulk by stevedores retained by the shipper.
- Hatches were sealed with steel pontoon covers overlaid by three tarpaulin layers bound with steel bonds; they remained closed throughout the voyage.
- Vessel arrived 3 July 1974 at Poro Point, La Union; hatches opened using ship’s gear.
- Discharge, Shortage, and Contamination
- Discharge conducted F.I.O.S. (Free In and Out Shipping), with PPI’s trucks covered and weighed en route to its warehouse; weather was variable, windy, occasionally rainy, and sandy along the route.
- CSCI surveyor’s draft surveys and PPI’s Certificate of Shortage/Damaged Cargo (18 July 1974) showed a shortage of approximately 94.839–106.726 M/T and about 18–23 M/T contaminated with dirt, sand and rust.
- PPI’s December 1974 claim to Soriamont Steamship Agencies (SSA) for ₱245,969.31 was not formally admitted; SSA denied involvement in discharge.
- Procedural History
- PPI filed suit 18 July 1975 in the CFI of Manila; the trial court applied the presumption of negligence on common carriers and ruled in favor of PPI.
- The Court of Appeals reversed (CA-G.R. CV No. 02736, 13 August 1991), holding the vessel a private carrier under the charter-party, thus negating the presumption.
- PPI elevated the case by petition for review to the Supreme Court.
Issues:
- Whether a time or voyage charter-party converts a common carrier into a private carrier, thereby removing the Civil Code’s presumption of negligence.
- If the presumption applies, whether respondent carrier proved the exercise of the extraordinary diligence required of a common carrier or established a fortuitous event or inherent risk.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)