Title
Trans-Asia Shipping Lines, Inc. vs. Court of Appeals
Case
G.R. No. 118126
Decision Date
Mar 4, 1996
Passenger sued shipping line for damages after vessel departed with one engine, causing distress and delay; court awarded moral and exemplary damages for breach of duty.

Case Summary (G.R. No. 245258)

Procedural History

The respondent filed Civil Case No. 91-491 in the Regional Trial Court (Branch 24, Cagayan de Oro), which rendered judgment dismissing the complaint. The respondent appealed to the Court of Appeals (CA-G.R. CV No. 39901), which reversed and awarded moral and exemplary damages, attorney’s fees, and costs. The petitioner sought review under Rule 45; the Supreme Court denied the petition, affirmed the Court of Appeals’ decision except that it set aside the award of attorney’s fees.

Issue Presented

The petitioner framed a question whether a passenger’s rights upon interruption of a vessel’s voyage are governed by the Civil Code provision on common carriers or by Article 698 of the Code of Commerce. The Supreme Court reformulated the issue more precisely as whether a common carrier is liable for damages to a passenger who disembarked after the vessel returned to port because of engine trouble when the vessel had sailed with only one operating engine.

Facts

The respondent purchased a ticket for the M/V Asia Thailand from Cebu City to Cagayan de Oro City and boarded on the evening of November 12, 1991. He observed repair work on an engine and the vessel departed with only one engine running. After an hour the vessel stopped near Kawit Island and dropped anchor; some passengers demanded return to Cebu City, and the captain complied. Upon return to Cebu City, the respondent and other passengers who wished to disembark were allowed to do so. The respondent then took another vessel of the petitioner the next day to reach Cagayan de Oro. He alleged fear, mental distress, additional expenses and loss of income caused by the petitioner’s conduct.

Trial Court Findings

The trial court treated the action as one for breach of contract and applied Civil Code provisions (Articles 1170, 1172, 1173 and Article 2201), concluding that liability for damages required fraud, negligence, or bad faith and that such elements were not shown. The trial court found that the petitioner did not conceal the engine defect, that passengers had the option to return their tickets, and that the respondent was negligent in disembarking without inquiry after a microphone announcement allowing disembarkation. The complaint was dismissed.

Court of Appeals Ruling

The Court of Appeals reversed, applying Article 1755 (common carrier’s duty to use utmost diligence) and several Civil Code provisions (Articles 2201, 2208, 2217, 2232). The CA concluded the vessel was unseaworthy and that the petitioner failed to exercise the required utmost diligence by sailing with one engine under repair. The CA found bad faith/wantonness and awarded P20,000.00 as moral damages, P10,000.00 as exemplary damages, P5,000.00 as attorney’s fees, and costs.

Supreme Court’s Legal Framework and Approach

The Supreme Court acknowledged the contract was one of common carriage, making the Civil Code provisions on common carriers the primary law, with the Code of Commerce and special laws to supply matters not regulated therein (Article 1766, Civil Code). Given the decision date, the 1987 Constitution governs the legal context. The Court focused on Article 1755 (utmost diligence of common carriers) and on the regime of damages under Title XVIII of the Civil Code (Articles 2199–2234 and related provisions).

Seaworthiness and Breach of Duty

Applying Article 1755, the Court held that the petitioner failed to exercise the requisite extraordinary/utmost diligence. The vessel had undergone repairs on a cylinder head, departed with only one functioning engine that later conked out, causing the vessel to drift and anchor—facts that established unseaworthiness and a breach of the carrier’s duty to ensure the ship was fit to sail. The carrier’s decision to commence the voyage under those conditions constituted actionable failure to observe the diligence required of common carriers.

Application of Article 698, Code of Commerce

The Court recognized that Article 698 of the Code of Commerce governs interruptions of a voyage after its commencement (fare pro rata, indemnity when interruption caused exclusively by the captain, etc.), and that Article 698 applies suppletorily under Article 1766 of the Civil Code. However, because the interruption was caused by the carrier’s failure to exercise utmost diligence (i.e., vessel disability stemming from the carrier’s conduct), Article 698 must be read together with the Civil Code provisions on damages (Articles 2199, 2200, 2201, 2208, and Article 21), making the carrier liable for pecuniary losses reasonably attributable to the non-performance.

Compensatory (Actual) Damages

The Court agreed with the CA that compensatory damages for delay were not properly proven. The respondent disembarked voluntarily and took another vessel the following day; any further delay in arrival resulted from his decision to disembark. Actual damages must be supported by evidence, and the respondent failed to prove loss of income or other pecuniary loss for the relevant date(s). Consequently, no award of compensatory damages was sustained.

Moral and Exemplary Damages

The Supreme Court concurred with the CA that moral and exemplary da

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