Escaño v. Natividad
REITERATIONFacts
The Antecedents: Plaintiff-appellee, Viuda e Hijos de F. Escaño, sought to enjoin the defendant, Joaquin Natividad, Collector of Customs of Cebu, from requiring them to provide one patron for each of their four vessels (Butuan, Villa de Soncillo, Luisa, and Ormoc). These vessels were less than 100 gross tons and propelled by machinery operating by the internal combustion of crude petroleum. Procedural History: The lower court granted the injunction, enjoining the defendant from requiring the plaintiff to provide a patron for the specified vessels. The Petition: The defendant appealed the lower court's decision, maintaining that the vessels, being propelled by machinery, were included in subsection (e) of section 1203 of the Administrative Code, which mandates specific officers for "steam vessels" of less than one hundred gross tons.
Issue(s)
Whether the phrase "steam vessel" in subsection (e) of section 1203 of the Administrative Code includes vessels propelled by gasoline or other internal combustion machinery. Whether the judgment of the lower court enjoining the defendant from requiring the plaintiff to provide one patron for each of the four specified vessels should be reversed.
Ruling
The judgment of the lower court is reversed, the complaint is dismissed, and the defendant is absolved from the complaint without special finding as to costs.
Ratio Decidendi
On the issue of whether "steam vessel" includes vessels propelled by gasoline or other internal combustion machinery: The Court held that the phrase "steam vessel" as used in subsection (e) of section 1203 of the Administrative Code is to be interpreted broadly to include any vessel propelled by machinery. The Court cited legal authorities, including U.S. Comp. St., 1901, which states that "The words 'steam vessel' shall include any vessels propelled by machinery." Furthermore, the case of The Nimrod, 173 Fed. Rep., 520, was referenced for the proposition that "Every vessel propelled by machinery is considered a 'steam vessel,' within the meaning of the navigation rules." This interpretation is based on the functional aspect of propulsion by machinery, rather than the specific type of engine or fuel used. The legislative intent behind such provisions is generally to ensure a certain standard of safety and competence in the operation of mechanically propelled vessels, irrespective of the precise technology employed. Therefore, vessels powered by internal combustion engines, such as those using gasoline or crude petroleum, fall within the purview of regulations intended for "steam vessels" when the context is the propulsion method. On the issue of reversing the lower court's judgment: Based on the interpretation that the plaintiff's vessels, being propelled by machinery, are considered "steam vessels" under the Administrative Code, the requirement for a patron applies. The lower court's injunction was therefore erroneous. The defendant, as Collector of Customs, was acting within his authority in enforcing the provisions of the Administrative Code. The stipulation of facts indicated that the vessels in question were less than one hundred gross tons. Consequently, the mandate of section 1203 (e) of the Administrative Code, which requires a patron for such vessels, must be complied with. The reversal of the lower court's decision is thus warranted to uphold the proper application of the law concerning the manning of vessels.
Main Doctrine
The term "steam vessel" in subsection (e) of section 1203 of the Administrative Code includes any vessel propelled by machinery, regardless of the specific type of fuel used.