Case Digest (G.R. No. 47447-47449)
Facts:
This case involves Teodoro R. Yangco, the petitioner, who owned the steamer S.S. Negros, which departed from the port of Romblon at around 1 PM on May 26, 1927, on its return voyage to Manila. Prior to departure, the captain was informed that Typhoon Signal No. 2 was raised, and passengers had called attention to the situation. The vessel was overloaded, with a passenger capacity of 123 but carrying approximately 180 passengers, in addition to various cargo including thirty sacks of crushed marble, a hundred sacks of copra, lumber, and packed baggage. After two hours of sailing, the ship encountered turbulent conditions between Banton and Simara, resulting in the captain’s decision to turn back to port. Unfortunately, during the turn, the vessel was struck by a massive wave, causing it to capsize and sink. Many passengers perished, notably Antolin Aldana and his son Victorioso, who were survived by Emilia Bienvenida and her family (respondents in G.R. No. 47447); Casiana LasernaCase Digest (G.R. No. 47447-47449)
Facts:
- Background and Vessel Details
- On May 26, 1927, at about one o’clock in the afternoon, the steamer S.S. Negros, owned by petitioner Teodoro R. Yangco, departed from the port of Romblon en route to Manila.
- The vessel set sail despite adverse weather conditions, as typhoon signal No. 2 was hoisted and noted by both the captain and the passengers.
- The ship was overloaded:
- The loadline indicated the water level was 6 to 7 inches below the maximum permissible mark.
- Upper decks were congested with baggage, trunks, and other equipment, while the hold was fully packed.
- Additionally carried were thirty sacks of crushed marble, about one hundred sacks of copra, and some lumber.
- Passenger capacity was exceeded by a significant margin, with 180 persons on board against an authorized capacity of only 123.
- Sequence of Events Leading to the Incident
- After approximately two hours of sailing, the vessel encountered strong winds and rough seas between the islands of Banton and Simara.
- As conditions worsened with the sea splashing the ladies’ dresses, the crew lowered the awnings.
- In an attempt to return to port, the captain ordered the vessel to turn left. However, the maneuver caused the steamer to be caught sidewise by a large wave, leading to its capsizing and sinking.
- Resulting Casualties and Legal Actions
- Many passengers died as a consequence of the shipwreck. Notable fatalities included:
- Antolin Aldana and his son Victorioso, whose surviving family members (wife Emilia Bienvenida, other children, and a brother-in-law) became respondents in G.R. No. 47447.
- Casiana Laserna, daughter of Manuel Laserna and P. A. de Laserna (respondents in G.R. No. 47448).
- Genaro Basana, son of Filomeno Basana (respondent in G.R. No. 47449).
- Separate civil actions were instituted by the respondents in the Court of First Instance of Capiz to recover damages for the wrongful deaths of the passengers.
- The initial awards were:
- P2,000 to the heirs of Antolin and Victorioso Aldana.
- P590 to the heirs of Casiana Laserna.
- P590 to the heirs of Genaro Basana.
- Upon appeal to the Court of Appeals, the judgments were affirmed except that the award to the Aldana heirs was increased to P4,000.
- Subsequent Legal Developments
- In a verified pleading, the petitioner sought to abandon the vessel along with all its equipment to the plaintiffs, while still preserving the right to appeal.
- The abandonment was denied, leading to further proceedings culminating in this appeal.
- The central factual question raised was whether the shipowner (or agent) could be held liable for damages—including wrongful deaths of passengers—even when the vessel was lost due to the negligence of its captain.
Issues:
- Fundamental Issue
- Whether a shipowner or agent, notwithstanding the total loss of the vessel arising from the captain’s negligence, may be held liable in damages for the resultant deaths of passengers.
- Statutory Basis and Legal Interpretations
- The applicability of Article 587 of the Code of Commerce, which provides the right of abandonment, thereby limiting the shipowner’s liability.
- Whether the language of Article 587—originally referring to indemnities related to the care of goods—extends to cover liabilities for injuries or wrongful deaths of passengers.
- Contractual Relationship Considerations
- If there exists a breach of contract of carriage due to the negligence resulting in a shipwreck, does maritime law limit the shipowner’s liability to his interest in the vessel?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)