Case Summary (G.R. No. 181833)
Background of the Case
- Petitioner: International Freeport Traders, Inc. (IFTI)
- Respondent: Danzas Intercontinental, Inc. (Danzas)
- Nature of the case: Liability of the consignee for electric charges, demurrage, and storage fees based on a service lease contract with a cargo handler.
- Shipment details: Toblerone chocolates and assorted confectioneries ordered from Jacobs Suchard Tobler Ltd. of Switzerland, with delivery terms "F.O.B. Ex-Works."
- Involvement of multiple parties: Jacobs, Danmar Lines, and Orient Overseas Container Line (OOCL) in the shipping process.
Sequence of Events
- Shipment initiated in March 1997, with Jacobs engaging Danmar for delivery.
- Danmar contracted OOCL for shipping; OOCL issued a non-negotiable master bill of lading.
- Goods arrived in Manila on May 14, 1997; Danzas informed IFTI of the arrival.
- IFTI prepared the import permit and advised Danzas to pick it up on May 20, 1997, but Danzas collected it on May 26, 1997.
- Danzas required original bills of lading and a bank guarantee from IFTI for the release of goods.
Dispute Over Charges
- IFTI claimed that letters of credit covered the shipment, while Danzas insisted on a bank guarantee.
- IFTI eventually applied for a bank guarantee, which was secured on May 23, 1997, but Danzas only collected it on June 6, 1997.
- IFTI requested the release of goods pending payment of charges, promising to pay within five days.
- Danzas released the goods on June 13, 1997, and later billed IFTI for P181,809.45 for handling the shipment.
Legal Proceedings
- Danzas filed a complaint against IFTI for non-payment.
- IFTI countered that it had no liability, asserting it was not privy to Danzas' hiring.
- The Metropolitan Trial Court (MeTC) ruled in favor of Danzas, ordering IFTI to pay the claimed amount.
- IFTI appealed, but the Regional Trial Court (RTC) dismissed the complaint.
Court of Appeals Decision
- The Court of Appeals reversed the RTC decision, finding that a perfected contract of lease of service existed between IFTI and Danzas.
- The court noted that IFTI's actions indicated acceptance of Danzas' services, including the provision of a bank guarantee.
Existence of Contract
- The court identified multiple contracts among IFTI, Jacobs, Danmar, and OOCL.
- Danzas acted as an agent for Danmar, responsible for the final delivery of goods to IFTI.
- IFTI's compliance with Danzas' requirements indicated acceptance of the service contract.
Elements of a Contract
- The court outlined the essential elements of a contract: consent, object, and cause.
- It concluded that the parties entered into a contract of lease of service for the clearing and delivery of goods.