Manahan v. People of the Philippines
REITERATIONFacts
The Antecedents: On June 5, 1965, the M/L Marli III, owned and operated by Marli Plywood and Veneer Corporation, left Bayawan, Oriental Negros for Cebu, carrying cargo and passengers. Among the passengers were Captain Jose Nuñez (skipper of Marli III), his wife, and other relatives, including his daughter Anabelle Nuñez, niece Consorcia Flores, and granddaughter Ilfreda Flores. While approaching the Lawis Lighthouse of Talisay, Cebu, around 1:00 AM on June 6, 1965, the M/L Marli III, under the command of Captain Nuñez and with Ildefonso Nierves at the wheel and Robustiano Torreque as lookout, was on course. The lookout spotted a green light of an approaching vessel. Captain Nuñez ordered Nierves to maintain course. Suddenly, the approaching vessel, identified as M/V Pioneer Butuan under Captain Jesus Manahan, showed a red light. Captain Nuñez ordered a hard port turn, but it was too late. The M/V Pioneer Butuan collided with the starboard side of the M/L Marli III, causing the latter to be swamped and submerged except for its top. The impact threw Anabelle Nuñez, Consorcia Flores, and Ilfreda Flores overboard, resulting in their drowning. Nelson Nuñez, Nimfa Macabante, and Captain Jose Nuñez sustained physical injuries. Procedural History: Captain Jesus Manahan and Captain Jose Nuñez were charged with Multiple Homicide, Multiple Physical Injuries, and Damage to Property thru Reckless Imprudence. The Cebu Special Board of Marine Accident conducted an investigation and recommended exoneration for both captains, finding Captain Manahan not negligent and Captain Nuñez acting in extremis. However, the trial court convicted both accused of multiple homicide and damage to property thru simple negligence, sentencing each to six months of arresto mayor and ordering them to pay solidary indemnity for the deaths and damages. The Court of Appeals affirmed this decision with modifications, increasing the indemnity for each death to P12,000.00 and correcting the portion regarding subsidiary imprisonment. The dispositive portion of the Court of Appeals' decision was later modified by the Supreme Court, increasing the indemnity for each death to P30,000.00. The Petition: Petitioner Jesus Manahan sought a review on certiorari of the Court of Appeals' decision, arguing that the lower court erred in disregarding the Board of Marine Inquiry's decision exonerating him and in denying his motion for a new trial.
Issue(s)
Whether the Court of Appeals erred in totally disregarding the decision of the Board of Marine Inquiry exonerating the petitioner from any criminal and civil liability. Whether the Court of Appeals erred in denying the petitioner's alternative prayer in his motion for reconsideration and/or new trial to remand the case to the trial court to enable him to present additional evidence to establish his innocence.
Ruling
The petition is DENIED, and the decision of the Court of Appeals is AFFIRMED, with the modification that the indemnity for each death is increased to Thirty Thousand (P30,000.00) pesos. In all other respects, the decision is AFFIRMED.
Ratio Decidendi
On Issue 1: The Supreme Court held that while administrative findings of fact are generally given weight if supported by substantial evidence, the decision of the Board of Marine Inquiry in this case was an exception. The Court found that the Board's conclusion of exoneration for Captain Manahan was not supported by substantial evidence. The records indicated that the vessels were displaying regulation lights, and Captain Manahan, as the commander of the M/V Pioneer Butuan, was bound to take necessary precautions to avoid collision. The Court noted that if the lookout of the Butuan had been alert, the lights of the Marli could have been observed earlier. Captain Manahan only noticed the Marli when it was dangerously near, showing a red light, indicating a failure to take necessary precautions. Furthermore, the Court found Captain Jose Nuñez equally negligent, as he was aware of the presence of the M/V Pioneer Butuan as early as 1:00 AM and had more than an hour to exercise utmost diligence in watching the movement of the incoming vessel and observing its lights to avoid a collision. The Court reiterated that findings of fact of the trial court, if supported by substantial evidence, are binding on the Supreme Court, and in this case, the trial court's findings were based on substantial evidence, thus warranting the conviction. On Issue 2: The Supreme Court affirmed the denial of the petitioner's motion for a new trial. The Court reiterated the requirement that for a new trial based on newly discovered evidence, the evidence must not have been discoverable and producible during the trial even with reasonable diligence. The Court noted that petitioner Jesus Manahan failed to appear during the trial as he was always out of the country on board a foreign vessel. His intended testimony could have been made available through depositions and discovery rules under the Rules of Court. There was no showing that he attempted to do so and failed. The Court also pointed out that the petitioner had a waiver of personal appearance, indicating he did not have a concrete basis for his defense and relied solely on his exoneration by the Board of Marine Inquiry. Moreover, the petition for new trial failed to state what the new evidence consisted of, and it is axiomatic that new trial is not granted if it will serve no purpose or if the defense is nil or ineffective. Additional evidence is not a ground for new trial.
Main Doctrine
The Supreme Court affirmed the conviction of both Captain Jesus Manahan and Captain Jose Nuñez for multiple homicide and damage to property through simple negligence, holding that both failed to exercise the necessary precautions to avoid a maritime collision, despite the conflicting findings of the Board of Marine Inquiry. The Court also modified the indemnity awarded to the heirs of the deceased.