Case Summary (G.R. No. 181643)
Facts of the Case
On November 22, 1981, the S/S "Galleon Sapphire" arrived carrying a shipment consigned to Caterpillar Far East Ltd. with Semirara Coal Corporation as the notify party. This shipment was insured under a marine insurance certificate issued by Summa Insurance. The loss occurred after the shipment was discharged to the custody of the arrastre operator, Metro Port, who issued good-order cargo receipts upon taking possession of the cargo. When Semirara inspected the shipment at its destination on March 9, 1982, they found that an essential bundle of PC8U blades was missing. Metro Port later issued a shortlanded certificate claiming that the bundle was missing at the time it received the shipment.
Initial Court Findings
The Regional Trial Court in Manila determined that Metro Port was liable for the loss because the shipment was confirmed to be missing while under its custody. This decision was based on the credibility of the good-order cargo receipts signed by representatives of both NGSC and Metro Port, which accurately described the condition of the shipment upon discharge. The trial court ruled in favor of Summa Insurance, ordering Metro Port to pay the full value of the lost shipment plus legal fees.
Appellate Court Ruling
On appeal, the Court of Appeals modified the trial court's decision, reducing Metro Port's liability to P3,500, citing provisions in the management contract between Metro Port and the Bureau of Customs, which limited the liability for lost cargo to a maximum of P3,500 per package unless the value was declared prior to the discharge of the goods. This ruling raised the issue of whether the failure to declare the shipment's true value absolved Metro Port of greater liability.
Issues Presented
Two primary issues arose in this case: (1) Whether Metro Port was legally liable for the loss of the shipment, and (2) If so, what the extent of that liability was, particularly in light of the management contract which stipulated a limitation on recovery unless the shipment’s value was properly declared.
Legal Framework and Analysis
An arrastre operator’s liability for lost shipments is akin to that of a common carrier and is governed by the diligence required in handling goods. The court emphasized that an arrastre operator, when entrusted with cargo, must exercise the diligence typical of warehousemen under the Civil Code. Although Metro Port was found to be liable for the loss of the shipment, the extent of that liability was restricted by the terms of
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Background of the Case
- The case revolves around the legal liability of an arrastre operator for the loss of a shipment in its custody.
- The petition for review was filed by Summa Insurance Corporation against the decision of the Court of Appeals, which modified the ruling of the Regional Trial Court regarding the liability of Metro Port Service, Inc. (formerly known as E. Razon, Inc.).
- The original decision required Metro Port to pay Summa Insurance Corporation for the value of the lost shipment, while the appellate court reduced the amount of liability.
Facts of the Case
- On November 22, 1981, the S/S "Galleon Sapphire" arrived at Pier 3, South Harbor, Manila, carrying a shipment consigned to Caterpillar Far East Ltd., with Semirara Coal Corporation as the notify party.
- The shipment included a bundle of PC 8 U blades, covered by marine insurance under Certificate No. 82/012-FEZ and Bill of Lading No. SF/MLA 1014.
- The shipment was discharged from the vessel into the custody of Metro Port, as indicated by good-order cargo receipts signed by representatives of both the shipping company and the arrastre operator.
- On February 24, 1982, the forwarder withdrew the shipment, but upon inspection at Semirara Island on March 9, 1982, a bundle of PC8U blades was found missing.
- Metro Port issued a shortlanded certificate on March 15, 1982, claiming the bundle was missing upon receipt from the vessel.
- Summa Insurance Corporation paid Semirara the value of the lost shipment and subsequently filed a complaint against Metro Port and NGSC for recovery of the amount.
Procedural History
- The Regional T