Title
Republic vs. Luzon Stevedoring Corporation
Case
G.R. No. L-21749
Decision Date
Sep 29, 1967
Luzon Stevedoring Corp. is held liable for damages to a bridge due to a barge collision, as the court found negligence without a valid force majeure defense.
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Case Digest (G.R. No. L-21749)

Facts:

  • Case: Republic of the Philippines vs. Luzon Stevedoring Corporation, G.R. No. L-21749
  • Date of Decision: September 29, 1967
  • Incident Date: August 17, 1960
  • Barge L-1892, owned by Luzon Stevedoring Corporation, was towed by tugboats "Bangus" and "Barbero."
  • Collision occurred with a wooden pile of the Nagtahan Bailey Bridge, causing significant damage and listing of the bridge.
  • The river was swollen and currents were swift due to heavy rainfall on August 15 and 16, 1960.
  • The Republic of the Philippines filed a lawsuit for damages amounting to P200,000 (Civil Case No. 44562) in the Court of First Instance of Manila.
  • Luzon Stevedoring Corporation denied liability, citing due diligence, force majeure, lack of capacity to sue by the plaintiff, and the bridge as an obstruction to navigation.
  • The lower court ruled on June 11, 1963, that the corporation was liable and ordered payment of P192,561.72 for repairs, plus legal interest.
  • The defendant appealed, claiming several errors by the lower court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the lower court's decision, finding no errors in its judgment.
  • Luzon Stevedoring Corporation was held liable for the damages caused by its employees.
  • ...(Unlock)

Ratio:

  • The ruling was based on the principle of negligence and the doctrine of "res ipsa loquitur," which infers negligence from the occurrence of an accident involving a controlled object.
  • The Nagtahan Bridge was a stationary structure with adequate navigation openings, and the collision raised a presumption of negligence against Luzon Stevedoring Corporation.
  • The court rejected the argument of force majeure, stating that the precautions taken indicated foreseeable ...continue reading

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