Case Digest (G.R. No. 191002) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Vector Shipping Corporation and Francisco Soriano v. American Home Assurance Company and Sulpicio Lines, Inc. (G.R. No. 159213, July 3, 2013), Vector Shipping Corporation (Vector), as the operator, and Francisco Soriano, as the registered owner of the motor tanker M/T Vector, entered on September 30, 1987 into a contract of affreightment with Caltex Philippines, Inc. (Caltex) for the carriage of petroleum products. Caltex insured its cargo for ₱7,455,421.08 under Marine Open Policy No. 34-5093-6 issued by respondent American Home Assurance Company (respondent). On the evening of December 20, 1987, the M/T Vector collided with the M/V Doña Paz, owned by Sulpicio Lines, Inc., in Tablas Strait, resulting in the sinking of both vessels and the total loss of Caltex’s cargo. On July 12, 1988, respondent indemnified Caltex in the full insured amount. On March 5, 1992, respondent sued Vector, Soriano, and Sulpicio Lines before the Regional Trial Court (RTC) of Makati City (Civil Case Case Digest (G.R. No. 191002) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Vessel Ownership
- Petitioners
- Vector Shipping Corporation – operator of the motor tanker M/T Vector
- Francisco Soriano – registered owner of the M/T Vector
- Respondents
- American Home Assurance Company – domestic insurer and subrogee of Caltex Philippines, Inc. (Caltex)
- Sulpicio Lines, Inc. – owner and operator of the M/V Doña Paz
- Contract of Affreightment and Insurance
- On September 30, 1987, Caltex contracted with Vector to transport petroleum cargo aboard the M/T Vector.
- Caltex insured the cargo with American Home Assurance under Marine Open Policy No. 34-5093-6 for P7,455,421.08.
- Collision, Loss and Indemnity Payment
- On December 20, 1987, M/T Vector collided with M/V Doña Paz near Dumali Point, Tablas Strait; both vessels sank and Caltex’s cargo was lost.
- On July 12, 1988, the insurer indemnified Caltex for P7,455,421.08 in full.
- Proceedings Below
- March 5, 1992 – Insurer filed Civil Case No. 92-620 against Vector, Soriano, and Sulpicio to recover the amount paid.
- December 10, 1997 – RTC Makati dismissed the complaint as barred by the four-year prescription for quasi-delict (Art. 1146, Civil Code).
- July 22, 2003 – Court of Appeals reversed: held Caltex‐Vector relationship contractual (ten-year prescription under Art. 1144), absolved Sulpicio, and cast Vector/Soriano jointly liable.
- September 12 & October 1, 2003 – Insurer’s partial motion for reconsideration held in abeyance; petitioners elevated the case to the Supreme Court.
Issues:
- Whether the insurer’s action filed on March 5, 1992 was already barred by prescription.
- Whether the cause of action is governed by the four-year prescription for quasi-delict or the ten-year period for obligations arising from contract or law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)