Case Digest (G.R. No. 191178) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Dante Cruz and Leonora Cruz vs. Sun Holidays, Inc. (G.R. No. 186312, June 29, 2010), petitioners Dante and Leonora Cruz filed a complaint on January 25, 2001 with the Regional Trial Court of Pasig City seeking damages for the death of their son, Ruelito C. Cruz, and his wife when the boat M/B Coco Beach III capsized en route from Puerto Galera to Batangas on September 11, 2000. Ruelito and his wife had availed themselves of a tour‐package contract with respondent, Sun Holidays, Inc., which operated the Coco Beach Island Resort and provided sea transportation as part of its services. Survivor Miguel C. Matute recounted that strong winds, heavy rains, and a sudden squall caused the vessel to list and overturn, trapping many under water. Rescue arrived after about forty‐five minutes; eight passengers, including the petitioners’ son and daughter‐in‐law, perished. At the time of his death, twenty‐eight‐year‐old Ruelito was employed abroad with a $900 monthly salary. By let Case Digest (G.R. No. 191178) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Petitioners Dante and Leonora Cruz filed a Complaint on January 25, 2001 against Sun Holidays, Inc. for damages arising from the death of their son Ruelito C. Cruz and his wife when M/B Coco Beach III capsized on September 11, 2000.
- The couple had availed themselves of a tour‐package contract at Coco Beach Island Resort in Puerto Galera, which included round‐trip ferry transport to Batangas.
- Incident Details
- Survivor Miguel Matute testified that departure scheduled for September 10 was postponed to the next day due to strong winds and heavy rains. On September 11, 26 resort guests, including Ruelito and his wife, boarded M/B Coco Beach III.
- Shortly after sailing into open seas amid worsening rain and wind, two successive large waves struck the vessel, causing it to capsize and submerge. Passengers struggled with life jackets; rescue arrived after about 45 minutes. Eight passengers, including Ruelito and his wife, perished.
- Pre‐litigation Correspondence and Positions
- By letter dated October 26, 2000, petitioners demanded indemnification of at least ₱4,000,000; respondent denied liability, deemed the incident fortuitous, and offered ₱10,000 upon waiver. Petitioners refused.
- Petitioners alleged respondent was a common carrier guilty of negligence for sailing despite PAGASA storm warnings. Respondent defended as a private carrier exercising utmost diligence, denied storm conditions, and counterclaimed for attorney’s fees.
- Procedural History
- RTC of Pasig City (Branch 267) dismissed both complaint and counterclaim on February 16, 2005; motion for reconsideration denied.
- The Court of Appeals affirmed on August 19, 2008, ruling respondent a private carrier that observed extraordinary diligence and that a squall (fortuitous event) caused the capsizing. Reconsideration was denied on January 16, 2009.
- Petitioners filed a Petition for Review with the Supreme Court, contending respondent is a common carrier and urging reversal.
Issues:
- Whether Sun Holidays, Inc. is a common carrier under Civil Code Article 1732.
- Whether respondent exercised the extraordinary diligence required of a common carrier in permitting M/B Coco Beach III to sail.
- Whether the capsizing was a fortuitous event absolving respondent of liability.
- What damages, costs, attorney’s fees, and interest petitioners are entitled to.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)