Case Summary (G.R. No. 47048)
Background of the Incident
SLI entered into a contract of carriage with ALC for the transportation of timber from Pugad, Lianga, Surigao del Sur. On the date of the incident, SLI’s tugboat and barge were unable to load the timber due to inclement weather. The following morning, stevedores employed by ALC, including Pamalaran, boarded the barge. Despite warnings from SLI’s employees about the dangers present in the storeroom, they proceeded to enter and subsequently suffered gas poisoning, leading to Pamalaran’s death.
Decisions of Lower Courts
The heirs of Pamalaran filed Civil Case No. 2864 against SLI, ALC, CBL Timber Corporation (CBL), and Ernie Santiago in the Regional Trial Court of Bohol, Branch 2, Tagbilaran City. The trial court found in favor of the plaintiffs, awarding actual and moral damages along with attorney's fees. The Court of Appeals upheld the trial court's decision, affirming that there were no justifiable reasons to reverse the lower court's ruling.
Petitioner’s Arguments
SLI challenged the Court of Appeals decision on several grounds:
- Pamalaran was not a passenger and thus SLI should not be liable as a common carrier.
- SLI’s employees were not negligent.
- SLI argued it should not be liable under Article 2180 of the New Civil Code.
- CBL and ALC should bear the liability instead of SLI.
- SLI’s counterclaims should have been granted.
Liability of Sulpicio Lines, Inc.
The Court of Appeals found that, despite Pamalaran not being a passenger, SLI held liability as a common carrier due to the contractual relationship with ALC. The presence of the stevedores was necessary for the transport of goods, indicating that SLI had knowledge and consent regarding their presence on the barge. Therefore, SLI bore the responsibility for their safety while onboard.
Negligence and Duty of Care
SLI argued that it had warned the stevedores against entering the storeroom. However, the appellate court found that SLI failed to adequately ensure the safety of the barge. It was determined that SLI's employees were not trained to manage situations that could jeopardize the stevedores' safety effectively. The court emphasized that proactive safety measures should have been taken to prevent unauthorized access to dangerous areas.
Validation of Findings and Claims
The appellate court's affirmance of the trial court’s findings, which were substantiated by evidence, formed the basis for not overturning the ruling. Both CBL and ALC were also held liable, reinforcing the principle of solidary liability among the defendants. The court dism
...continue readingCase Syllabus (G.R. No. 47048)
Case Overview
- This case involves a petition for review on certiorari under Rule 45 of the Revised Rules of Court, filed by Sulpicio Lines, Inc. (petitioner) against the Court of Appeals and Jacinta L. Pamalaran (respondents).
- The appeal seeks to reverse the Decision dated April 8, 1992, of the Court of Appeals in CA-G.R. CV No. 21919, which upheld the decision of the Regional Trial Court of Bohol, Branch 2, in favor of the heirs of the deceased Leoncio L. Pamalaran.
Factual Background
- A contract of carriage was established between Sulpicio Lines, Inc. (SLI) and AGO Lumber Company (ALC) for the transportation of timber from Lianga, Surigao del Sur.
- On March 17, 1976, SLI dispatched the tugboat "MT Edmund" and the barge "Solid VI" to Lianga. Loading operations could not commence due to heavy rain.
- The following morning, stevedores from CBL Timber Corporation (CBL), hired by ALC, attempted to board the "Solid VI" despite warnings regarding dangerous gas and heat in the storeroom filled with copra.
- Leoncio L. Pamalaran, one of the stevedores, entered the storeroom, lost consciousness, and subsequently died due to gas poisoning.
Procedural History
- The heirs of Pamalaran filed Civil Case No. 2864 for damages against SLI, CBL, ALC, and Ernie Santiago in the Regional Trial Court.
- The trial court ruled in favor of the plaintiffs, awarding:
- Actual and compensatory damages of ₱40,000.00
- Moral damages of ₱50,000.00
- Attorney's fees of ₱20,000.