Case Digest (G.R. No. 160219)
Facts:
On December 19, 1987, spouses Cornelio and Anacleta Macasa, accompanied by their eight-year-old grandson Ritchie, boarded the MV Doña Paz—owned and operated by Sulpicio Lines, Inc.—in Tacloban, Leyte, bound for Manila. In the early hours of December 20, the passenger ferry collided with the MT Vector, an oil tanker owned by Vector Shipping Corporation and Francisco Soriano, in Tablas Strait. Only twenty-six persons survived; the bodies of Cornelio, Anacleta and Ritchie were never recovered. Bereft of reliable information from Sulpicio Lines, the Macasa family conducted a private search before filing, on October 2, 1991, a Complaint for Damages against Sulpicio Lines in the Regional Trial Court (RTC), Branch 17 of Davao City. They alleged breach of contract of carriage and sought P800,000 in civil indemnity, P100,000 for lost personal effects, P600,000 moral damages, P100,000 exemplary damages, and P100,000 for costs and attorney’s fees. Sulpicio Lines denied negligence, assertedCase Digest (G.R. No. 160219)
Facts:
- The Collision and Immediate Aftermath
- On December 19–20, 1987, MV Doña Paz (operated by Sulpicio Lines) en route from Tacloban to Manila collided at sea with MT Vector (owned by Vector Shipping and Francisco Soriano), laden with petroleum products, off Dumali Point in the Tablas Strait.
- The collision resulted in over 4,000 deaths; only 26 persons survived. Spouses Cornelio and Anacleta Macasa and their grandson Ritchie perished and their bodies were never recovered.
- The Macasas’ Search and Filing of Suit
- Relatives of the victims (the Macasas) went to Sulpicio Lines’ offices to inquire about the incident but were denied information and left to conduct their own futile search for the bodies.
- Before filing suit, Sulpicio Lines offered ₱250,000.00 in total as settlement for the three deaths, which the Macasas rejected. On October 2, 1991, the Macasas sued Sulpicio Lines for breach of contract of carriage, claiming:
- ₱800,000.00 civil indemnity for the three deaths and unearned income;
- ₱100,000.00 actual/compensatory damages for lost personal effects;
- ₱600,000.00 moral damages;
- ₱100,000.00 exemplary damages; and
- ₱100,000.00 attorney’s fees and costs.
- Third-Party Complaint and Lower Court Decisions
- Sulpicio Lines impleaded Vector Shipping, Soriano, and Caltex Philippines, Inc. (charterer of MT Vector), alleging MV Doña Paz was seaworthy and the collision was solely MT Vector’s fault as per the Board of Marine Inquiry (BMI).
- RTC Decision (May 5, 1995):
- Awarded the Macasas ₱200,000.00 civil indemnity, ₱100,000.00 actual damages, ₱500,000.00 moral damages, ₱100,000.00 exemplary damages, and ₱50,000.00 attorney’s fees;
- Ordered third-party defendants jointly and severally liable to reimburse and indemnify Sulpicio Lines for these amounts.
- CA Decision (September 24, 2003):
- Exonerated Caltex;
- Deleted the ₱100,000.00 actual damages;
- Reduced civil indemnity to ₱150,000.00;
- Affirmed all other aspects of the RTC ruling.
Issues:
- Issues Raised by Vector Shipping and Soriano
- Whether the pending BMI decision (not yet final and executory) can bind the courts.
- Which vessel—MV Doña Paz or MT Vector—was solely at fault given contrasting speeds, crew competence, and radar warnings.
- Whether Vector and Soriano can be held to indemnify Sulpicio Lines under “culpa contractual,” given the carrier’s duty of extraordinary diligence.
- Whether both vessels should be declared mutually at fault absent clear proof.
- Other Contentions
- Whether prior SC ruling in Caltex (Philippines), Inc. v. Sulpicio Lines, Inc. is res judicata.
- Whether the CA’s deletion of actual damages and reduction of civil indemnity lack justification.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)