Case Summary (G.R. No. 15652)
Factual Background of the Case
On July 23 and September 18, 1918, the Ynchausti Steamship Company was contracted by the Government to transport two consignments of mineral oil from Manila to Aparri, Cagayan. Following the delivery of these consignments, the consignee claimed that one case from each shipment was delivered empty, leading to a deduction of P22.53 from the total amount due to the petitioner based on findings by the Insular Auditor, who attributed the shortages to the negligence of the petitioner. The petitioner consistently contested this deduction and sought the complete payment of P82.79 for freight services.
Legal Framework and Procedural History
The relevant legal framework governing the transaction includes provisions from the Administrative Code, particularly Section 646, which emphasizes the obligations of carriers and consignees concerning notations of loss or damage on bills of lading. The controversy was presented to the court based on an agreed statement of facts after the respondents answered with denials, except for the admission of the parties' residency and character.
Allegations of Negligence and Burden of Proof
In this case, the petitioner argued that the alleged shortages were due to circumstances unknown to them and not attributable to any negligence on their part. The court noted that the respondents denied this allegation and found no supporting evidence in the agreed statement of facts. It concluded that the presumption of negligence arose from the consignee's notations of the loss on the bills of lading, as mandated by Section 646, obliging the petitioner to provide proof to counter this presumption.
Judicial Findings and Conclusion
The court highlighted the principle that a carrier is prima facie liable for goods delivered in good condition but arriving
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Case Overview
- The case involves a petition for a writ of mandamus filed by the Ynchausti Steamship Company against the Insular Purchasing Agent and the Insular Auditor of the Philippine Islands.
- The petitioner sought to compel the respondents to sign and deliver a warrant for the amount of P82.79, which the petitioner claimed was due for freight services rendered in transporting mineral oil for the Government.
Facts of the Case
- The petitioner, Ynchausti Steamship Company, was employed by the Government to transport two consignments of mineral oil from Manila to Aparri, Cagayan.
- The first consignment was on July 23, 1918, consisting of 30 cases of 'White Rose' mineral oil.
- The second consignment was on September 18, 1918, consisting of 96 cases of 'Cock' brand mineral oil.
- Both shipments were documented with a Government bill of lading, acknowledging receipt of the goods in apparent good condition.
- Upon delivery, the consignee noted that one case from each shipment was delivered empty, prompting a claim of loss.
- The Acting Insular Purchasing Agen