Wednesday, November 15, 2023

Case Digest: Negros Navigation v. CA, G.R. No. 110398

 

Negros Navigation v. CA, G.R. No. 110398, November 7, 1997

Subject: Transportation Law


FACTS

In April of 1980, private respondent Ramon Miranda purchased from the Negros Navigation Co., Inc. four special cabin tickets (#74411, 74412, 74413 and 74414) for his wife, daughter, son and niece who were going to Bacolod City to attend a family reunion. The tickets were for Voyage No. 457-A of the M/V Don Juan, leaving Manila at 1:00 p.m. on April 22, 1980.

The ship sailed from the port of Manila on schedule.

Unfortunately, Don Juan collided off the Tablas Strait in Mindoro, with the M/T Tacloban City, an oil tanker owned by the Philippine National Oil Company (PNOC) and the PNOC Shipping and Transport Corporation (PNOC/STC). As a result, the M/V Don Juan sank. Several of her passengers perished in the sea tragedy. The bodies of some of the victims were found and brought to shore, but the four members of private respondents' families were never found.

Private respondents filed a complaint in RTC of Manila against Negros Navigation, PNOC, and PNOC/STC, seeking damages for the death of Ardita de la Victoria Miranda, 48, Rosario V. Miranda, 19, Ramon V. Miranda, Jr., 16, and Elfreda de la Victoria, 26.

RTC ruled in favor of private respondent and ordered the defendants (petitioner) to pay jointly and severally the damages. On appeal, CA affirmed RTC’s decision with some modification. Hence this petition.

ISSUE

Whether or not the crew members of petitioner are grossly negligent in the performance of their duties; and is Mecenas vs IAC is binding in this case.

RULING

Yes, the crew members of petitioner are grossly negligent in the performance of their duties and the decision promulgated by the court in Mecenas vs IAC is binding in this case.

Under the law, a common carrier is bound to carry the passengers safely as far as human care and foresight can provide, using the utmost diligence of very cautious persons, with a due regard for all the circumstances.

In this case, applying the principle of stare decisis, decision on the Mecenas case was applicale. Negros Navigation was found equally negligent in tolerating the playing of mahjong by the ship captain and other crew members while on board the ship and failing to keep the M/V Don Juan seaworthy so much so that the ship sank within 10 to 15 minutes of its impact with the M/T Tacloban City. In addition, the ship was overloaded evidenced by the Certificate of Inspection issued by the Philippine Coast Guard Commander at Iloilo City stated that the total number of persons allowed on the ship was 864 but there were 1,004 on board the vessel when it sank. Taking these circumstances together, and the fact that the M/V Don Juan, as the faster and better-equipped vessel, could have avoided a collision with the PNOC tanker, this Court held that even if the Tacloban City had been at fault for failing to observe an internationally recognized rule of navigation, the Don Juan was guilty of contributory negligence.

No comments:

Post a Comment

Case Digest: General Santos Coca-Cola Plant Free Workers Union – TUPAS vs Coca-Cola Bottlers Philippines., Inc., CA and NLRC, G.R. No. 178647

  General Santos Coca-Cola Plant Free Workers Union – TUPAS vs Coca-Cola Bottlers Philippines., Inc., CA and NLRC,  G.R. No. 178647,  Februa...