G.R. No. 211454 - Maunlad Transportation, Incorporated vs. Camoral

A contract of carriage was entered into between petitioner Sulpicio Lines, Inc. (SLI) and AGO Lumber Company (ALC) for the transport of ALC’s timber from Pugad, Lianga, Surigao del Sur.
Under the terms of the contract, the transportation of the lumber required the use of petitioner’s tugboat "MT Edmund" and barge "Solid VI."

On March 17, 1976, SLI dispatched the tugboat and barge to Lianga to load ALC’s timber; however, heavy downpour hindered the loading process that day.
The following day, stevedores hired by ALC from CBL Timber Corporation (CBL) boarded the barge "Solid VI" to commence the loading operation.

Despite warnings issued by petitioner’s employees regarding the gas and heat generated by the copra stored in the barge’s holds, the stevedores proceeded.
One stevedore, after entering the storeroom, fell unconscious due to gas exposure.
Subsequently, another stevedore, identified as Leoncio L. Pamalaran, also entered, lost consciousness, and ultimately died of gas poisoning.

A claim for damages was filed by the heirs of Leoncio L. Pamalaran in Civil Case No. 2864 before the Regional Trial Court of Bohol, Branch 2, Tagbilaran City, against petitioner SLI, CBL, ALC, and Ernie Santiago.
The trial court ruled in favor of the plaintiffs awarding:

On appeal, the Court of Appeals (Decision dated April 8, 1992, CA-G.R. CV No. 21919) affirmed the lower court’s decision, holding that no justifiable reason existed to reverse the ruling.

Leoncio L. Pamalaran was never a passenger of SLI and thus SLI could not be held liable as a common carrier.
Neither SLI nor its employees were negligent in the events leading to Pamalaran’s death.
SLI was not liable under Article 2180 of the New Civil Code.
The liability for the death should fall on CBL and/or ALC, not on SLI.
SLI’s just and valid counterclaims and cross claims should have been granted.

The Court of Appeals, however, relied on the precedent in Canas v. Dabatos, noting that even in the absence of a formal passenger-carrier relationship, a vessel owner may still be held liable as a common carrier if persons are on board with the owner’s knowledge and consent.

Evidence showed that petitioner’s employees had warned the laborers about the hazard; however:

The warnings were deemed insufficient in lieu of ensuring that the barge was safe for entry.
Petitioner’s employees lacked proper training and detailed instructions to secure and supervise the entry into the barge’s bodega.
The failure to exercise due diligence in preventing unauthorized entry into the storeroom was central to the petitioner's negligence.

The trial and appellate courts found petitioner liable for damages due to this negligence and its resultant common carrier responsibilities.

Whether petitioner Sulpicio Lines, Inc. can be held liable as a common carrier for the death of Leoncio L. Pamalaran despite the latter not being classified as a passenger under the contract of carriage.
Whether the actions and omissions of petitioner’s employees, particularly the lack of sufficient precautions to secure the barge from unsafe entry, constitute negligence warranting liability for the resultant death.
Whether petitioner’s defenses—including the claim of non-passenger status of the victim, absence of negligence, and non-applicability of Article 2180 of the New Civil Code—are tenable and sufficient to absolve it of liability.
Whether the counterclaims and cross claims filed by petitioner against the other defendants should succeed, given the established solidary liability among the parties involved.