Sunday, March 10, 2024

Case Digest: Go Chan vs. Aboitiz, 98 Phil 179

 

Go Chan vs. Aboitiz, 98 Phil 179

Subject: Transportation Law


FACTS

The plaintiff shipped 240 cases of milk and the corresponding freight was paid; that the cargo was transhipped on the S. S. Snug Hitch and arrived at the port of Cebu in 1947 with 24 cases shortlanded; that a timely claim for the short-landed cargo of 24 cases was presented by the plaintiff to the defendant but the latter asked to defer the claim; that when the 24 cases arrived, Go Tiong, the General Manager of the plaintiff corporation did not receive them because they were no longer in cases but in sakes, and that the cans were no longer fit for human consumption - they were damaged and rusty; that the delay in payment was due to the request of the defendant for amicable settlement which later, the defendant refused to pay.

The defendant answered that the loss was due to a peril of the sea and that anyway the action was barred because more than one year had elapsed from February 1947 to May 1950 when the complaint was filed.

The court of first instance of Cebu rendered judgment for the plaintiff. Having failed in a motion to reconsider, defendant perfected its appeal.

ISSUE

Whether or not the action has already prescribed.

RULING

Yes, the action has prescribed.

Under existing jurisprudence, the prescriptive period of one year established in the Carriage of Goods by Sea Act modified pro tanto the provisions of Act No. 190 as to goods transported to and from Philippine ports in foreign trade.

In this case, the transaction under consideration is covered by the Carriage of Goods by Sea Act, and since this is a special act, its provisions must of necessity limit or restrict a law of general application. Moreover, since the action was not filed within one year from February, 1947 when the cargo was delivered or should have been delivered, the law discharged this defendant from all liability in connection with the carriage of said goods.

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