Villanueva v. Barber Wilhelmsen Line
REITERATIONFacts
The Antecedents: Plaintiff Cenon Villanueva was the consignee of two bales of rayon remnants. The goods were discharged from SS/TORREADOR on June 14, 1957, and placed in the custody of the Manila Port Service (arrastre operator). The goods were delivered to Villanueva with a shortage, valued at P879.96. Villanueva filed a provisional claim on July 8, 1957. The port service rejected the claim, citing paragraph 15 of the Management Contract between the Manila Port Service and the Bureau of Customs, which required claims to be filed within fifteen (15) days from the date of discharge. Procedural History: Villanueva filed an action against the carrier, ship agent, port service, and arrastre operator for the recovery of the value of the shortage and attorney's fees. The carrier and ship agent claimed discharge from responsibility upon delivery to the port service. The port service and arrastre operator invoked paragraph 15 of the Management Contract. The case was submitted upon a stipulation of facts, with the sole issue being the binding effect of the 15-day claim period on the consignee. The Court of First Instance of Manila ruled that the 15-day period was not binding and rendered judgment in favor of Villanueva. The Petition: The defendants Manila Port Service and Manila Railroad Co., Inc. appealed the decision.
Issue(s)
Whether the 15-day claim period stipulated in Paragraph 15 of the Management Contract between the Manila Port Service and the Bureau of Customs is binding upon a consignee who is not a signatory to said contract.
Ruling
The Supreme Court reversed the decision of the Court of First Instance. It held that the consignee became bound by the terms of the Management Contract, including the 15-day period for filing claims, by taking delivery of the goods and using the documents that incorporated the contract's provisions. Consequently, the defendants-appellants were absolved from the complaint.
Ratio Decidendi
On Issue 1: The Supreme Court held that the consignee is legally bound by the provisions of the Management Contract. Applying the rule in Northern Motors, Inc. vs. Prince Line, the Court found that even if a consignee is not a signatory to the Management Contract, he becomes a party thereto when he, through his broker, obtains a delivery permit and gate pass and uses them to demand delivery of the goods. By using these documents, which specifically incorporate the terms of the Management Contract by reference, the consignee accepts the stipulations contained therein. The Court further reasoned, citing Mendoza vs. Philippine Air Lines, that a party's demand for delivery under a contract constitutes a notice of acceptance of the stipulations in his favor. Consequently, a consignee cannot take advantage of the Management Contract to obtain his goods and then reject the prescriptive periods for claims found within the same contract. Since Villanueva used the gate pass and delivery permit to obtain the rayon remnants, he made himself a party to the contract and is barred from bringing suit because his claim was filed more than 15 days after the discharge of the goods. Therefore, the lower court erred in holding that the 15-day period was not binding on the consignee.
Main Doctrine
A consignee, by taking delivery of goods and utilizing the processes and documents (delivery permit, gate pass) that incorporate by reference or substantially reproduce the provisions of the Management Contract between the arrastre operator and the Bureau of Customs, becomes bound by the terms and conditions of said contract, including the period for filing claims, even if not a signatory thereto.