Case Summary (G.R. No. L-19383)
Factual Background
On November 1, 1951, while S/S "Peter J. McGuire" was anchored in Manila Bay, its refrigeration facilities failed, prompting a representative of the petitioner to contact the Insular Ice and Cold Storage Plant to arrange storage for perishable food provisions. A compartment was leased for this purpose at a daily rate of PHP 19.00. After storing the provisions, they were found to be damaged by rodents when recovered on November 6, 1951. A Bureau of Quarantine examination revealed rat infestations, leading to the declaration that the provisions were unfit for consumption. Subsequent efforts by the Bureau’s Rodent Control Section resulted in the capture of 66 rats from the storage area in the weeks following the incident.
Procedural History
Following the incident, United States Lines Company filed a complaint in the Court of First Instance of Manila to recover PHP 2,262.38 for damages and an additional PHP 600.00 for attorney’s fees. The Court ruled in favor of the petitioner, adjudicating the respondent liable for damages, but the San Miguel Brewery appealed the decision. The Court of Appeals reversed the initial judgment regarding damages while upholding the dismissal of the counterclaim for PHP 4,000.00 made by the respondent.
Legal Issue
The focus of the appeal to the Supreme Court was whether a lessor of a cold storage facility could be held liable for damage to foodstuffs stored by a lessee, specifically due to rodent infestations.
Analysis of the Court of Appeals Decision
The Court of Appeals expressed doubt regarding the evidence presented by the petitioner, particularly questioning the credibility of a single witness's testimony without additional corroborative evidence about the presence of rats at the time of the storage. However, the Supreme Court deemed the evidence of the captured rats significant, concluding that they were likely present before the foodstuffs were removed. This finding supported the conclusion that the deterioration of the provisions was due to the existing rodent infestation.
Ruling on Lessor Liability
The Supreme Court scrutinized the applicability of the legal precedent cited by the Court of Appeals, specifically the case of Yap Kim Chuan vs. Tiaoqui. The court determined that the reasoning used in that case was improperly generalized. Unlike that instance, which involved damage from an act of God (torrential rain), the presence of rodents constituted a straightforward b
...continue readingCase Syllabus (G.R. No. L-19383)
Case Overview
- The case involves a petition for review by certiorari filed by United States Lines Company against San Miguel Brewery, Inc. to contest the decision of the Court of Appeals.
- The petitioner, United States Lines Company, is a foreign corporation licensed to operate in the Philippines and acts as the agent for the vessel S/S "Peter J. McGuire."
- The respondent, San Miguel Brewery, Inc., operates the Insular Ice and Cold Storage Plant in Manila.
- The case centers around the deterioration of foodstuffs stored in the cold storage plant, allegedly due to rodent infestation.
Factual Background
- On November 1, 1951, the S/S "Peter J. McGuire" faced refrigeration issues while anchored in Manila Bay, prompting the need for storage of perishable supplies.
- Mr. Finch, an officer of the petitioner, contacted Chua Seng, manager of People's Food Supply, who recommended San Miguel Brewery's cold storage plant for storage.
- The petitioner leased a compartment in the cold storage plant for a daily rental of P19.00, where the food provisions were stored from November 1 to November 6, 1951.
- Upon retrieval on November 6, 1951, the foodstuffs were found to be gnawed, soiled, and contaminated by rodents.
Inspection and Findings
- Dr. Isagani Chanco from the Bureau of Quarantine inspected the contaminated foodstuffs and confirmed the presence of rat bites and excreta, declaring the provisions unfit for consumption.
- Following this, government employees caught 66 rats in the storage plant f