Case Digest (G.R. No. L-37750)
Facts:
In Sweet Lines, Inc. v. Hon. Bernardo Teves, decided on May 19, 1978 under the 1973 Philippine Constitution, petitioner Sweet Lines, Inc., an inter-island shipping company, sought a writ of prohibition with preliminary injunction to restrain Hon. Bernardo Teves, Presiding Judge of the CFI of Misamis Oriental, Branch VII, from further proceedings in Civil Case No. 4091. Private respondents Leovigildo D. Tandog, Jr. (an attorney) and Rogelio Tiro (a contractor) purchased passage tickets Nos. 011736 and 011737 on December 31, 1972 for Voyage 90 from Cagayan de Oro City to Tagbilaran City via M/S “Sweet Hope.” Upon discovering the vessel was diverted to Surigao, respondents were redirected to M/S “Sweet Town,” which was already full, forcing them to “hide at the cargo section.” During the trip they were exposed to extreme heat and dust, and their originally purchased tickets were not honored, compelling them to buy new tickets. They filed suit for P110,000.00 damages and breach of c...Case Digest (G.R. No. L-37750)
Facts:
- Underlying controversy and petition for prohibition
- Sweet Lines, Inc. filed on October 3, 1973 an original action for prohibition with preliminary injunction in the Supreme Court against Hon. Bernardo Teves, Presiding Judge of the CFI of Misamis Oriental (Branch VII).
- The petition sought to restrain the respondent judge from proceeding with Civil Case No. 4091 (“Leovigildo D. Tandog, Jr. and Rogelio Tiro v. Sweet Lines, Inc.”) after denial of petitioner’s Motion to Dismiss for improper venue and its Motion for Reconsideration.
- Ticket purchase and voyage conditions
- On December 31, 1972, respondents Tandog and Tiro bought passage tickets Nos. 011736 and 011737 at Sweet Lines’ Cagayan de Oro branch for Voyage 90 bound for Tagbilaran via Cebu.
- Upon discovering the original vessel was rerouted, they were relocated to M/S “Sweet Town,” compelled to ride concealed in the cargo hold, allegedly exposed to heat and dust, and forced to pay additional fares when original tickets were not honored. They sued for P110,000 damages for breach of contract of carriage.
- Procedural history in the trial court
- Petitioner moved to dismiss based on Condition No. 14 printed on the ticket rear: “Any and all actions … shall be filed in the competent courts in the City of Cebu.” The trial court denied both the motion and its reconsideration.
- Petitioner escalated to the Supreme Court; a TRO was issued on November 20, 1973, and the petition was given due course on January 18, 1974. Both parties filed memoranda thereafter.
Issues:
- Validity and enforceability of Condition No. 14 printed on the back of the passage tickets
- Can a common carrier engaged in inter-island shipping unilaterally stipulate by fine-print ticket condition that all actions arising from the contract of carriage be filed exclusively in a specified venue (City of Cebu)?
- Does such a stipulation constitute a valid waiver of venue when passengers have no bargaining power and no meaningful opportunity to examine or negotiate the condition?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)