Case Digest (G.R. No. L-19383)
Facts:
United States Lines Company v. San Miguel Brewery, Inc., G.R. No. L-19383. April 30, 1964, the Supreme Court En Banc, Labrador, J., writing for the Court.United States Lines Company (petitioner) was the local agent of the vessel S/S "Peter J. McGuire"; San Miguel Brewery, Inc. (respondent) operated the Insular Ice and Cold Storage Plant in Manila. On November 1, 1951, while the vessel was anchored in Manila Bay its refrigeration failed. Petitioner’s officer Finch, following a recommendation from Chua Seng of the People’s Food Supply, arranged with Jose H. Martinez (in charge of the plant) to lease Compartment A in Room I‑B on the ground floor at P19.00 per day to store the ship’s perishable provisions.
The provisions were placed in the leased compartment on November 1 and withdrawn on November 6 to be returned to the ship; petitioner then discovered they had been gnawed, soiled and damaged by rodents. Petitioner reported the matter to the Bureau of Quarantine; Dr. Isagani Chanco inspected the provisions aboard the vessel and found evidence of rat bites, gnawings and rat excreta, and recommended disposal at sea. The Bureau’s Rodent Control Section later caught 66 rats in Room I‑B between November 19 and December 15, 1951.
Petitioner sued respondent in the Court of First Instance of Manila for P2,262.38 in damages and P600 attorney’s fees; respondent filed affirmative defenses and counterclaimed for P4,000. The trial court found for petitioner and awarded P2,262.38 with 6% interest from judgment, P500 attorney’s fees, and costs, dismissing respondent’s counterclaim. The Court of Appeals reversed insofar as it ordered respondent to pay petitioner but affirmed dismissal of the counterclaim, expressing doubt about t...(Pro-only)
Issues:
- Did the evidence sufficiently prove that rats were present in Room I‑B at the time the provisions were stored and that they caused the damage?
- Is a lessor of a cold storage plant liable to a lessee for deterioration of goods stored in the leased premises because of rodents, absent fraud or bad fait...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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