Vector Shipping Corp. v. Macasa
REITERATIONFacts
The Antecedents: On December 19, 1987, spouses Cornelio and Anacleta Macasa, and their grandson Ritchie, boarded the MV Doña Paz, owned by Sulpicio Lines, Inc., bound for Manila. On December 20, 1987, the MV Doña Paz collided with the MT Vector, an oil tanker owned by Vector Shipping Corporation and Francisco Soriano, which was loaded with gasoline. The collision occurred near Dumali Point, Tablas Strait. Only twenty-six persons survived. Cornelio, Anacleta, and Ritchie were among the victims whose bodies were never recovered. Procedural History: The Macasas filed a Complaint for Damages arising out of breach of contract of carriage against Sulpicio Lines before the RTC, alleging negligence. Sulpicio Lines filed a Third-Party Complaint against Vector Shipping, Soriano, and Caltex Philippines Inc. The RTC ruled in favor of the Macasas, holding Sulpicio Lines liable and ordering Vector Shipping, Soriano, and Caltex to jointly and severally reimburse Sulpicio Lines. The CA modified the RTC decision by exonerating Caltex and deleting actual damages, reducing civil indemnity. Vector Shipping and Soriano appealed to the Supreme Court. The Petition: Petitioners Vector Shipping and Soriano sought reversal of the CA decision, raising issues regarding the binding effect of the Board of Marine Inquiry (BMI) findings, the sole fault of MT Vector, and whether they could be held liable to indemnify Sulpicio Lines given that Sulpicio Lines' liability arose from breach of contract of carriage. They argued that MV Doña Paz was at fault due to navigational errors and lack of competent officers on the bridge.
Issue(s)
Whether the decision of the Board of Marine Inquiry (BMI), which was pending with the Department of National Defense, could be binding upon the court. Whether MT Vector was solely at fault for the collision, considering the size and speed of both vessels and the absence of eyewitnesses. Whether Vector Shipping and Soriano could be held liable to indemnify Sulpicio Lines for breach of contract of carriage, as Sulpicio Lines' liability stemmed from its duty to exercise extraordinary diligence. Whether both vessels should be declared mutually at fault, with each bearing its own loss, in the absence of clear and convincing proof of sole fault.
Ruling
The Supreme Court denied the petition for review on certiorari, affirming the decision of the Court of Appeals. The Court held that the issues raised by the petitioners were essentially questions of fact, which are outside the scope of a Rule 45 petition. The Court also took judicial notice of its previous ruling in Caltex (Philippines), Inc. v. Sulpicio Lines, Inc., which held Vector Shipping and Soriano liable to reimburse and indemnify Sulpicio Lines.
Ratio Decidendi
On the binding effect of BMI findings: The Court noted that the BMI findings are administrative in nature and do not preclude civil liability. Furthermore, the Court took judicial notice of its decision in Caltex (Philippines), Inc. v. Sulpicio Lines, Inc., which had already sustained the CA ruling that Vector Shipping and Soriano are liable to reimburse and indemnify Sulpicio Lines. The Court also pointed out that a previous petition filed by Francisco Soriano and Vector Shipping Corporation was denied for failure to show reversible error by the CA, which had upheld the third-party liability of the petitioners. The Court reiterated its respect for the factual findings of the CA, which were affirmed by the RTC, and found no exceptions to warrant disturbing these findings. On the issue of fault: The Court reiterated that a petition for review on certiorari under Rule 45 is limited to questions of law. Petitioners' insistence that MV Doña Paz was at fault required a review and determination of the weight, credence, and probative value of the evidence presented, which had already been passed upon by the RTC and CA. Therefore, the matter was essentially factual and outside the Court's purview in a Rule 45 petition, as the Supreme Court is not a trier of facts. The Court emphasized that the test is whether the appellate court can determine the issue without reviewing or evaluating the evidence. On the liability of Vector Shipping and Soriano for indemnification: The Court affirmed the CA's finding that MT Vector was unseaworthy and that its negligent officers and crew caused the collision. The Court cited its ruling in Caltex (Philippines), Inc. v. Sulpicio Lines, Inc., where it was held that MT Vector fits the definition of a common carrier and that the carrier is obliged to impliedly warrant the seaworthiness of the vessel. The failure to maintain a seaworthy vessel constitutes a breach of the duty prescribed in Article 1755 of the Civil Code. The Court found that MT Vector was carrying expired licenses and permits, was not properly manned, and had defects in its ignition system, all indicating unseaworthiness. On the denial of the petition: The Court found no cogent reason to deviate from its consistent rulings in previous cases that upheld the third-party liability of the petitioners. The Court also stated that awaiting the review of BMI findings by the Department of National Defense would unduly prolong the agony of the victims and result in a delay of justice, which the Court cannot allow. The Court reiterated its respect for the factual findings of the CA and RTC, finding no substantial matters that would alter the outcome of the case.
Main Doctrine
The Supreme Court affirmed the Court of Appeals' decision, holding that the petitioners (Vector Shipping Corporation and Francisco Soriano) are liable to reimburse and indemnify Sulpicio Lines for damages awarded to the victims of the MV Doña Paz and MT Vector collision. The Court reiterated that findings of fact of the Court of Appeals are generally binding and conclusive, and that the issue of fault in the collision is a question of fact, not of law, thus outside the scope of a petition for review on certiorari.