American President Lines, Ltd. v. Court of Appeals
REITERATIONFacts
The Antecedents: On July 30, 1987, American President Lines, Ltd. (APL), a foreign shipping company, received and loaded a shipment of one submersible jockey pump in three boxes on board its vessel 'President Washington' in Los Angeles, California, for transport to Manila, Philippines, in favor of Lindale Development Corporation. APL, through Forwarders Direct Container Lines, Inc., issued a clean Bill of Lading No. CHI-MNL-120. The shipment was insured by FGU Insurance Corporation (private respondent) against all risks for P481,842.24. The vessel transshipped the cargo in Hong Kong and it arrived in Manila on September 6, 1987, aboard the vessel MS 'Partas'. Upon discharge, one box was found in bad order condition, showing signs of tampering, and was turned over to Marina Port Services, Inc. (Arrastre). Ten days later, the shipment was withdrawn by a broker and delivered to the consignee. Upon examination, one box was found short of one piece waste cone and one piece main relief, valued at P28,248.58. The consignee filed claims with APL, Arrastre, and LCM Brokerage Co., Inc., which were denied. The consignee then sought payment from the insurer, FGU Insurance Corporation, which paid P28,248.58. FGU Insurance Corporation, as subrogee, filed a complaint for recovery of sum of money against APL, Arrastre, and LCM Brokerage Co., Inc. Procedural History: The Regional Trial Court (RTC) found APL liable for actual damages in the amount of P28,248.58 plus attorney's fees. The Court of Appeals (CA) affirmed the RTC's decision, holding that under a through bill of lading, APL undertook responsibility for the entire carriage and could be called upon for indemnification for any loss, regardless of where it occurred. The Petition: APL filed a petition for review on certiorari with the Supreme Court, questioning the CA's decision. APL argued that the bill of lading was issued solely by the freight forwarder, not by APL through its agent, and thus the freight forwarder assumed the liabilities of a common carrier. APL claimed it was only obligated to carry the shipment up to Hong Kong and denied liability for damages occurring thereafter, suggesting MS 'Partas' should be liable.
Issue(s)
Whether a freight forwarder, in issuing a bill of lading, assumes the obligations and liabilities of a common carrier, and whether a common carrier is bound by the terms of a house bill of lading issued by a freight forwarder. Whether the Supreme Court can review factual findings of the lower courts regarding the issuance of the bill of lading in a petition for review on certiorari. On the nature of a through Bill of Lading.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the issue of who issued the bill of lading is a factual matter, which cannot be raised in a petition for review on certiorari under Rule 45 of the Rules of Court. The Court reiterated that findings of fact by the trial and appellate courts, when affirmed by the Court of Appeals, are generally accorded great weight and finality.
Ratio Decidendi
On the issue of whether a freight forwarder assumes the obligations and liabilities of a common carrier and whether a common carrier is bound by a house bill of lading issued by a freight forwarder: The Court found that the petitioner, American President Lines, Ltd. (APL), was primarily disputing the factual finding of the lower courts that APL, through Forwarders Direct Container Lines, Inc., issued the clean Bill of Lading No. CHI-MNL-120. Petitioner claimed the freight forwarder issued the bill of lading on its own. The Court emphasized that the resolution of who actually issued the bill of lading is a question of fact. Petitioner's arguments that the freight forwarder assumed liabilities and that APL was only obligated to carry the shipment up to Hong Kong were predicated on this disputed factual premise. The Court noted that petitioner itself raised factual issues by asserting that the findings of fact of the respondent courts were "manifestly erroneously (sic) and unsupported by evidence" and were "mere conjectures." On the issue of whether the Supreme Court can review factual findings of the lower courts: The Court reiterated the well-established rule that factual questions may not be raised in a petition for review on certiorari under Rule 45 of the Revised Rules of Court. Section 1 of Rule 45 explicitly states that the petition "shall raise only questions of law which must be distinctly set forth." The Court's function is limited to reviewing errors of law committed by the lower courts. To delve into factual findings would convert the Supreme Court into a trier of facts, which is contrary to its intended role. Therefore, the Court was constrained from further scrutiny of the findings of fact made by the trial and appellate courts, especially since these findings were affirmed by the Court of Appeals and are generally accorded great weight, if not finality. On the nature of a through Bill of Lading: The Court, in affirming the appellate court's ruling, implicitly upheld the principle that the nature of a through Bill of Lading is that the carrier undertakes to be responsible for the carriage of goods by successive ocean carriers from the point of loading to the final destination. The first carrier is responsible for the whole carriage, and the claimant may call upon the first carrier for indemnification for any loss along the route, whether or not the loss took place in the first carrier's custody. This principle was applied by the CA to hold APL liable, even assuming the loss occurred while in the custody of MS 'Partas'.
Main Doctrine
A carrier issuing a through bill of lading is responsible for the entire carriage from the port of loading to the final destination, even if the loss or damage occurred while the cargo was in the custody of a subsequent carrier. Factual issues, such as who issued the bill of lading, are generally not reviewable in a petition for review on certiorari under Rule 45 of the Rules of Court.