Case Summary (G.R. No. 18957)
Incident Overview
The facts indicate that the Isabel set sail from Manila destined for Balayan, Batangas, carrying its cargo of rice. After departing, around 10 PM on February 10, 1920, both vessels spotted each other when they were approximately one to two miles apart. While both vessels were operating at a speed of roughly six miles per hour, a critical decision by the mate of the Antipolo to alter its course became an essential point of contention. Upon realizing the risk of collision, the mate of the Antipolo turned hard to starboard, a maneuver which could have averted disaster had the mate of the Isabel responded similarly.
Negligence Attribution
The Court of First Instance determined that negligence could be attributed to both vessels, albeit of differing degrees. The mate of the Antipolo was found negligent for allowing the vessel to close in on the Isabel without taking evasive measures sooner, while the mate of the Isabel was particularly faulted for making an ill-advised turn to port instead of maintaining a course that could have avoided the collision. The court noted that exhaustion on the part of the mate on the Isabel, who had been on duty continuously, may have contributed to the lapse in judgment.
Legal Principles and Application
The court applied Article 827 of the Code of Commerce, which addresses situations where both vessels are at fault and stipulates that they shall be solidarily responsible for damages incurred. Given that the Isabel sustained a total loss and therefore could not contribute to any liability, the court determined that full responsibility for the damages fell to the Philippine Steamship Company, Inc. The decision reinforced that liability under Article 827 is not exclusively dependent on the ability to identify a single culpable party; rather, it accommodates circumstances where both vessels share blame.
Conclusion and Judgment Affirmation
The appellate court found no error in the initial ruling from the Court of First
...continue readingCase Syllabus (G.R. No. 18957)
Case Overview
- The case involves a claim by the Government of the Philippine Islands against the Philippine Steamship Company, Inc. for the recovery of P14,648.25, the alleged value of 911 sacks of rice lost at sea due to a collision.
- The incident occurred on February 11, 1920, between the steamer Antipolo, owned by the defendant company, and the vessel Isabel, which was carrying the rice consigned to various points in the south.
Facts of the Case
- The vessel Isabel left the port of Manila at approximately 10 o'clock on the night of February 10, 1920, heading for Balayan, Batangas.
- After about four hours of travel, while near San Nicolas Light, both the Isabel and Antipolo were spotted by their respective crew members at a distance of 1.5 to 2 miles apart.
- Each vessel was traveling at a speed of approximately 6 miles per hour, converging towards one another.
- As the situation became critical, the mate of the Antipolo correctly decided to turn the helm to starboard to avoid a collision, while the mate of the Isabel mistakenly turned hard to port, leading to the vessels