Title
Republic vs. Lorenzo Shipping Corporation
Case
G.R. No. 153563
Decision Date
Feb 7, 2005
The Philippines, CARE, and NTFC sued LSC for breach of carriage after NTFC claimed non-delivery of goods. Courts ruled LSC exercised due diligence, dismissing claims but removing damages and fees awarded to LSC.

Case Digest (G.R. No. 153563)
Expanded Legal Reasoning Model

Facts:

  • Contractual Agreement: On June 5, 1987, the Republic of the Philippines, through the Department of Health (DOH), and the Cooperative for American Relief Everywhere, Inc. (CARE) entered into an agreement. CARE would acquire donations of non-fat dried milk and other food products from the United States government, and the Philippines would transport and distribute these goods to beneficiaries.
  • Contract of Carriage: The government contracted National Trucking and Forwarding Corporation (NTFC) to handle the transportation. NTFC shipped 4,868 bags of non-fat dried milk through Lorenzo Shipping Corporation (LSC) from September to December 1988.
  • Delivery of Goods: Upon arrival at Zamboanga City, LSC’s agent, Efren Ruste Shipping Agency, unloaded the goods and delivered them to NTFC’s warehouse. Consignee Abdurahman Jama presented certified true copies of the bills of lading instead of the originals. Delivery receipts were signed by Jama or his subordinates.
  • Claim of Non-Delivery: NTFC claimed it did not receive the goods and filed a formal claim for non-delivery on March 11, 1989. LSC responded that the goods had been delivered to Jama. Jama later resigned as NTFC’s branch supervisor.
  • Legal Action: The government, CARE, and NTFC sued LSC for breach of contract of carriage. The Regional Trial Court (RTC) ruled in favor of LSC, dismissing the complaint and awarding LSP actual damages and attorney’s fees. The Court of Appeals affirmed the RTC’s decision.

Issues:

  • Presumption of Fault: Is LSC presumed negligent as a common carrier for the loss or deterioration of the goods?
  • Damages and Attorney’s Fees: Are the awards of actual damages and attorney’s fees to LSC justified?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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