Case Digest (G.R. No. 220400) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Annie Tan v. Great Harvest Enterprises, Inc., decided on March 20, 2019 under G.R. No. 220400, petitioner Annie Tan, a trucking contractor, was engaged by respondent Great Harvest Enterprises, Inc. on February 3, 1994 to haul 430 bags of soya beans valued at ₱230,000.00 from Tacoma Integrated Port Services, Inc. in Port Area, Manila, to Selecta Feeds in Camarin, Novaliches, Quezon City. Tan’s employee, Rannie Sultan Cabugatan, loaded and delivered the cargo, but Selecta Feeds refused to accept it. Great Harvest then instructed Cabugatan to reroute the shipment to its Malabon warehouse. The truck never arrived; upon inquiry, Tan initially promised to locate the goods but later admitted they were missing. Tan reported the truck stolen; the National Bureau of Investigation recovered it cannibalized in Cavite, without cargo, and Tan spent over ₱200,000.00 to repair the vehicle. She filed criminal complaints against Cabugatan and Rody Karamihan for theft. Meanwhile, Great Harvest Case Digest (G.R. No. 220400) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract for Carriage and Loss of Goods
- On February 3, 1994, Great Harvest Enterprises, Inc. (Respondent) engaged Annie Tan (Petitioner) to transport 430 bags of soya beans valued at ₱230,000.00 from Tacoma Integrated Port Services, Inc., Manila to Selecta Feeds, Quezon City.
- Upon delivery, Selecta Feeds rejected the shipment. Great Harvest then directed Petitioner’s driver to deliver the goods to Great Harvest’s warehouse in Malabon, but the truck and cargo never arrived.
- Attempts to Recover and Criminal Proceedings
- Petitioner reported the missing truck to the Western Police District Anti-Carnapping Unit and the NBI; the truck was found cannibalized in Cavite with no cargo. She spent over ₱200,000.00 repairing it.
- Petitioner filed a complaint against her employees Rannie Sultan Cabugatan and Rody Karamihan for theft; criminal charges followed.
- Civil Actions and Appeals
- Great Harvest sent demand letters on March 2 and April 26, 1994, for payment of the lost soya beans; Petitioner refused, prompting a ₱230,000.00 complaint for sum of money filed June 2, 1994. Petitioner denied liability and claimed deviation of instructions.
- The RTC of Quezon City (January 3, 2012) found a verbal hauling contract and held Petitioner liable for ₱230,000.00 plus 12% interest, ₱50,000.00 attorney’s fees, and costs. The CA (March 13, 2015; September 15, 2015) affirmed, citing Petitioner’s failure to exercise extraordinary diligence. Petitioner then filed a Rule 45 Petition for Review on Certiorari.
Issues:
- Substantive Issue
- Whether Annie Tan, as a common carrier, should be held liable for the value of the soya beans stolen by her driver.
- Procedural Issue
- Whether factual questions may be raised in a Rule 45 Petition for Review on Certiorari under the “misapprehension of facts” exception.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)