Thursday, January 18, 2024

Case Digest: Campagnie vs. Hamburg-Amerika, G.R. No. L-10986

 

Campagnie vs. Hamburg-Amerika, 36 Phil. 590, G.R. No. L-10986, March 31, 1917

Subject: Transportation Law


FACTS

This is an action by the Compagnie de Commerce et de Navigation D'Extreme Orient, a corporation duly organized and existing under and by virtue of the laws of the Republic of France, with its principal office in the city of Paris, France, and a branch office in the city of Saigon, against the Hamburg Amerika Packetfacht Actien Gesellschaft, a corporation duly organized under and by virtue of the laws of the Empire of Germany, with its principal office in the city of Humburg, Germany, and represented in the city of Manila by Behn, Meyer & Company (Limited), a corporation. The plaintiff seeks to recover the full value if Saigon of a certain cargo of the steamship Sambia, alleged to amounts to the sum of P266,930, Philippine currency, and prays that certain proceeds of the sale of said cargo, amounting to P135,766.01, now on deposit in this court, be applied on said judgment, and that judgment be rendered in favor of the plaintiff and against the defendant for such sum as may represent the difference between the said amount and the value of the payment and delivery unto plaintiff from said deposit, with legal interest and costs of suit.

RTC decided in favor of the plaintiff and against the defendant and further, that the plaintiff to recover from the defendant the sum of P60,841.32 for the actual damages suffered by the plaintiff by the defendant's breach of the charter party in evidence, with legal interest thereon from the date of the filing of the complaint in this case until paid. The defendant's cross-complaint is hereby dismissed with the costs of this case against the defendant. Both plaintiff and defendant appealed to the Supreme Court as to the damages imposed.

ISSUE

Whether or not the master of the Sambia, when he fled from the port of Saigon and took refuge in the port of Manila, had reasonable grounds to apprehend that his vessel was in danger of seizure or capture by the public enemies of the flag under which he sailed.

RULING

Yes, the master of the Sambia had reasonable grounds to apprehend that his vessel was in danger of seizure or capture by the public enemies of the flag under which he sailed.

Under the general provisions of maritime law  and the express provisions of article 7 of the charter party, the act of God, the king's enemies, arrests and restraints of princes, rulers and people, perils of the seas, barratry of the master and crew, pirates, collisions, strandings, loss or damage from fire on board, in hulk or craft, or on shore; and act, neglect, default or error in judgment whatsoever of pilots, master, crew or other servant of the shipowners in the navigation of the steamer; and all and every the dangers and accidents of the seas, canals and rivers, and of navigation of whatever nature or kind always mutually excepted.

In this case, there is no question as to the necessity, arising out of the presence of enemy cruisers on the high seas which compelled the Sambia, once she had left the port of Saigon, to take refuge in the port of Manila and to stay there indefinitely pending the outcome of the war. The deviation of the Sambia from the route prescribed in her charter party, and the subsequent abandonment by the master of the voyage contemplated in the contract of affreightment, must be held to have been justified by the necessity under which he was placed to elect that course which would remove and preserve the vessel from danger of seizure by the public enemies of the flag under which she sailed; and that neither the vessel nor her owners are liable for the resultant damages suffered by the owner of the cargo.

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