Case Summary (G.R. No. 193914)
Factual Background
On February 23, 1996, the cargo ship M/V "Diamond Rabbit," owned by Seven Brothers Shipping Corporation, was docked at PICOP Pier amidst windy and rough seas. Prior to approaching the Pier, the vessel was safely anchored at the causeway of Bislig, but the Master decided to leave for the Pier despite the unfavorable weather conditions. During this maneuver, a lifeboat attempted to assist the vessel's docking, but the heaving line attached to the vessel broke, leading to its propeller becoming entangled with the mooring rope. Consequently, the vessel became uncontrollable and drifted into the coal-conveyor facility owned by DMC-Construction Resources, Inc., leading to the destruction of the facility.
Procedural History
On March 5, 1996, DMC sent a demand letter to Seven Brothers for damages arising from the incident. When the petitioner did not respond, DMC filed a complaint for damages on March 23, 1998, in the Regional Trial Court (RTC) of Makati City. The RTC found that the coal-conveyor facility was indeed damaged due to the captain's negligence, ruling that no force majeure was present since the captain was aware of the bad weather but chose to dock the vessel anyway. The RTC awarded DMC actual damages amounting to P3,523,175.92.
Court of Appeals Decision
Dissatisfied with the RTC's decision, Seven Brothers appealed to the Court of Appeals (CA), which eventually dismissed the appeal and affirmed the RTC's ruling, albeit modifying the nature of damages awarded from actual to nominal damages, citing a lack of sufficient proof presented by DMC to substantiate its claim for actual damages due to the absence of actual receipts.
Issues Raised
The primary legal issue escalated to the Supreme Court was whether the CA erred in awarding nominal damages after determining that the actual damages awarded by the RTC were unfounded. Seven Brothers contended that nominal damages should not simply replace unproven actual damages. Conversely, DMC claimed that nominal damages were justified due to the confirmed violation of its property rights resulting from Seven Brothers' negligence.
The Supreme Court's Ruling
The Supreme Court ruled in favor of DMC, stating that temperate damages, rather than nominal damages, should be awarded due to the established fact of injury to DMC’s conveyor facility. The Court emphasized that while actual
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Case Overview
- This case involves a Rule 45 appeal dated November 18, 2010, challenging the Decision and Resolution of the Court of Appeals (CA) in CA-G.R. CV No. 69819.
- The case concerns the liability of the petitioner, Seven Brothers Shipping Corporation, for damages to the respondent, DMC-Construction Resources, Inc., following an incident involving the cargo ship M/V "Diamond Rabbit."
Factual Background
- On February 23, 1996, the M/V "Diamond Rabbit," owned by Seven Brothers, was docked at PICOP Pier in Mangagoy, Surigao del Sur.
- The weather conditions were windy (10 to 20 knots) with rough seas (6 to 8 feet waves), despite the vessel being safely anchored prior to the incident.
- The vessel's Master decided to move the ship from the safe anchorage to the pier, during which the heaving line broke, causing the mooring rope to entangle in the propeller, rendering the ship uncontrollable.
- The Master attempted to secure the vessel with the starboard anchor, but the severe weather caused the vessel to drift and collide with several structures, including DMC's coal conveyor facility.
Procedural History
- On March 5, 1996, DMC sent a demand letter to Seven Brothers for damages.
- When payment was not received, DMC filed a Complaint for damages on March 23, 1998.
- The Regional Trial Court (RTC) ruled in favor of DMC, stating that no force majeu