Case Summary (G.R. No. 37661)
Applicable Law
The pertinent legal framework includes the Civil Code of the Philippines, particularly Articles 1733, 1734, and 1735, concerning the liabilities of common carriers, and the 1987 Philippine Constitution.
Proceedings and Initial Rulings
The Regional Trial Court of Manila (Branch 36) ruled on November 20, 1989, that Aboitiz Shipping Corporation was liable for the total value of the lost cargoes instead of invoking the doctrine of limited liability. The Court of Appeals affirmed this ruling and denied the petitioner’s motion for reconsideration. Aboitiz subsequently elevated the case to the Supreme Court, questioning the applicability of the limited liability doctrine.
Supreme Court Decision of May 2, 2006
On May 2, 2006, the Supreme Court issued a decision denying Aboitiz's petition for lack of merit. The Court upheld the lower courts’ findings and ruled that Aboitiz was liable for the full damages. The contention that the Court modified the principles set forth in prior cases, such as GAFLAC and Monarch, was central to the petitioner’s arguments.
Motion for Reconsideration
In response to the Supreme Court’s decision, Aboitiz filed a Motion for Reconsideration. They raised two primary issues: first, that the Court's decision disregarded previous rulings that limited Aboitiz's liability, and second, that it violated Section 4(3) of Article VIII of the 1987 Constitution, which stipulates that only the Court En Banc has the authority to modify or reverse decisions rendered by divisions of the Court.
Respondent's Position and Supreme Court's Rejection
The respondent argued that the total liability was justified due to Aboitiz's negligence. The Supreme Court found Aboitiz's Motion for Reconsideration to be unpersuasive, stating that it merely reiterated arguments already considered and rejected in the May 2006 decision. It emphasized that the facts of this case distinguished it from the precedents cited by Aboitiz.
Distinction from Prior Decisions
The Court clarified that the circumstances that led to the sinking of M/V P. Aboitiz were different from those in GAFLAC, where the shipowner was not found negligent. In this case, both the ship captain and crew were deemed negligent, and as a result, the appl
...continue readingCase Syllabus (G.R. No. 37661)
Case Overview
- This case involves a petition filed by Aboitiz Shipping Corporation (petitioner) against New India Assurance Company, Ltd. (respondent) concerning the liability for lost cargo due to the sinking of the vessel M/V P. Aboitiz.
- The case was decided on August 24, 2007, under G.R. No. 156978, by the Second Division of the Supreme Court of the Philippines.
Background Facts
- On October 31, 1980, M/V P. Aboitiz sank during its voyage from Hong Kong to Malaysia.
- The lost cargo was insured by the respondent, which subsequently indemnified General Textile, Inc., the consignee of the cargo, and was thereby subrogated to its rights against the petitioner.
- Respondent filed a civil suit (Civil Case No. 82-1475) against the petitioner seeking recovery for actual damages amounting to P142,401.60, along with attorney's fees, exemplary damages, and costs of suit.
Trial Court Proceedings
- On November 20, 1989, the Regional Trial Court of Manila, Branch 36, ruled against the petitioner, holding it liable for the total value of the lost cargo.
- The trial court declined to apply the doctrine of limited liability, which would restrict the petitioner’s liability to its pro rata share in the insurance proceeds.
Appellate Court Ruling
- The Court of Appeals affirmed the trial court’s decision in full, rejecting the petitioner’s motion for reconsideration.
Supreme Court Decision (May 2, 2006)
- The Supreme Court denied the petition for lack of merit and upheld the Court of Appeals'