Case Summary (G.R. No. L-14651)
Background of the Incident
On May 3, 1970, at 3:50 a.m., a maritime accident occurred between the M/V "Don Carlos," owned by Carlos A. Go Thong and Company, and the M/S "Yotai Maru," a Japanese-registered vessel, near Caballo Island. The "Don Carlos," sailing south from Manila to Cebu, collided with the "Yotai Maru," causing significant damage to the latter, specifically a three-centimeter gaping hole on its portside, leading to cargo flooding and consequent financial damages.
Initial Legal Proceedings
Insurance companies representing the consignees of the damaged cargo filed lawsuits against Go Thong in the Court of First Instance of Manila. Two civil cases ensued: Civil Case No. 82567 presided over by Judge Bernardo P. Fernandez and Civil Case No. 82556 overseen by Judge Serafin R. Cuevas. Both judges found the officers and crew of the "Don Carlos" negligent, awarding damages to the insurance claimants.
Court of Appeals Decisions
Go Thong appealed both cases to the Court of Appeals, resulting in varying outcomes. Judge Fernandez's decision in C.A.-G.R. No. 61320-R was affirmed, while Judge Cuevas's decision in C.A.-G.R. No. 61206-R was later reversed, attributing fault to the "Yotai Maru." This marked a critical divergence in the legal findings.
Issues on Res Judicata
The insurance companies contest the Sison decision’s failure to observe the principle of res judicata, asserting that the two cases share sufficient identity of parties and cause of action, warranting adherence to the previously settled judgments against Go Thong. Go Thong argues that the identity of parties is lacking due to different co-petitioners in the actions.
Supreme Court's Analysis of Res Judicata
The Supreme Court concluded that despite subtle differences in parties, res judicata applies due to shared interest and the fact that both cases targeted the same defendant for similar causes of action rooted in the same incident. The earlier definitive ruling by the Court of Appeals in favor of petitioners should, therefore, bind the later proceedings.
Rejection of Go Thong’s Arguments
Go Thong’s defense, which included invoking a compromise agreement between the "Yotai Maru" and Go Thong about fault, was dismissed by the Court. The Court emphasized that such agreements do not equate to admissions of liability, which further weakened Go Thong’s position.
Review of Negligence
The Court closely examined Judge Cuevas’s conclusions identifying three key aspects of negligence by the "Don Carlos":
- Failure to Follow Navigation Rules: The "Don Carlos" did not adhere to Rule 18(a) of the International Rules of the Road, altering its course inappropriately.
- Lack of Proper Look-Out: No dedicated look-out was maintained aboard the "Don Carlos," which compromised
Case Syllabus (G.R. No. L-14651)
Case Overview
- Date of Decision: May 20, 1991
- Court: Supreme Court of the Philippines
- Case Number: G.R. No. 56294
- Parties: Petitioners - Smith Bell and Company (Philippines), Inc. and Tokyo Marine and Fire Insurance Co., Inc.; Respondents - The Court of Appeals and Carlos A. Go Thong and Co.
Facts of the Case
- On May 3, 1970, at 0350 hours, a collision occurred between the inter-island vessel "Don Carlos," owned by Carlos A. Go Thong and Company, and the Japanese merchant vessel "Yotai Maru."
- The "Don Carlos" was sailing south toward Cebu, while the "Yotai Maru" was approaching Manila from Kobe, Japan.
- The collision resulted in a three-centimeter gaping hole on the portside of the "Yotai Maru," flooding its cargo, for which the consignees were compensated by their insurance companies.
Procedural History
- Insurance companies, having been subrogated to the interests of the consignees, filed two separate cases in the Court of First Instance of Manila against Go Thong for damages.
- Civil Case No. 82567 was presided over by Judge Bernardo P. Fernandez, while Civil Case No. 82556 was overseen by Judge Serafin R. Cuevas. Both cases utilized the same evidence and focused on the same issues regarding the collision.
- Both judges found the officers and crew of the "Don Carlos" negligent, holding Go Thong liable for damages.
- Go Thong appealed both decisions to the Court of Appeals, resulting in two separate cases: C.A.-G.R. No. 61320-R and C.A.-G.R. No.