Cruz v. Philippine Iron Constr.
REITERATIONFacts
The Antecedents: F.F. Cruz and Company, Inc. (F.F. Cruz) was engaged by the Department of Public Works and Highways to construct a government pier in Brooke's Point, Palawan. During the project, F.F. Cruz brought several barges and a tugboat to the site. Anchor Metals Corporation (AMC), through a bareboat charter from Philippine Iron Construction & Marine Works, Inc. (PICMW), owned Barge "Florida" and leased tugboat M/T "Jasaan." In November 1988, a typhoon, Welpring, struck the area. F.F. Cruz's Barge 609 and Barge Piling Rig "Pilipino" sank, and Barge 1001 collided with driven piles. AMC's tugboat Jasaan, while towing Florida to safety, also drifted ashore. Procedural History: Following the incident, the master of F.F. Cruz's tugboat M/T "Imma" filed a marine protest alleging that Jasaan and Florida caused damage to F.F. Cruz's vessels and the driven piles. The Board of Marine Inquiry (BMI) absolved AMC, PICMW, and others, attributing fault to F.F. Cruz's crew for failing to secure their barges. The Philippine Coast Guard affirmed the BMI's findings. F.F. Cruz then filed a complaint for damages against AMC and PICMW with the Regional Trial Court (RTC), which found AMC and PICMW solidarily liable. The RTC ordered them to pay F.F. Cruz substantial actual damages and attorney's fees. AMC and PICMW appealed. The Court of Appeals (CA) found AMC liable for damages but mitigated its liability due to F.F. Cruz's contributory negligence, reversing the RTC's finding of solidarity and absolving PICMW. Both parties moved for reconsideration, which were denied. The Petition: F.F. Cruz and AMC filed consolidated petitions for review on certiorari under Rule 45 of the Rules of Court, challenging the CA's decision and resolution. F.F. Cruz contested the CA's finding of contributory negligence, while AMC questioned its liability for actual damages. The Supreme Court reiterated that Rule 45 petitions are generally limited to questions of law and that it is not a trier of facts. While acknowledging exceptions, such as conflicting findings between the CA and the trial court, the Court found that neither petitioner demonstrated the required showing of gross or extraordinary misperception or manifest bias by the CA to warrant a re-examination of the factual findings. The Court ultimately denied both petitions, affirming the CA's decision.
Issue(s)
Whether the Supreme Court can review factual findings of the Court of Appeals in a petition for review on certiorari under Rule 45. Whether the Court of Appeals erred in finding F.F. Cruz guilty of contributory negligence. Whether Anchor Metals Corporation (AMC) is liable for the damages caused by its vessels.
Ruling
The petitions are denied. The Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the scope of review under Rule 45: The Supreme Court reiterated that a petition for review under Rule 45 of the Rules of Court is limited to questions of law, and factual questions are not proper subjects of such an appeal. The Court emphasized that it is not a trier of facts and will not re-examine evidence already considered by lower courts. While exceptions exist, such as when the CA's factual findings contradict those of the trial court, the petitioner must demonstrate manifest bias or extraordinary misperception of evidence by the CA. Both F.F. Cruz and AMC failed to meet this stringent standard. On F.F. Cruz's contributory negligence: The Court affirmed the CA's finding that F.F. Cruz was guilty of contributory negligence. This conclusion was based on the factual findings of the Board of Marine Inquiry (BMI), which were supported by substantial evidence. The BMI report detailed F.F. Cruz's failure to properly secure Barge 609 and Barge 1001, and their proximity to the driven piles. The crew did not move the barges to a safer distance from the driven piles, despite the imminent typhoon, leading to damage when the mooring lines snapped and the vessels collided with the piles, causing them to sink or be damaged. The CA correctly relied on these BMI findings, which were supported by evidence, to hold F.F. Cruz partly responsible. On AMC's liability: The Court agreed with the CA's finding that AMC's vessels were responsible for the allision. The CA's conclusion was based on the positive testimonies of F.F. Cruz's witnesses and the admissions of Jasaan's captain and Florida's patron that they moved during the typhoon. This contradicted the BMI's exoneration of AMC, which the CA correctly disregarded as being based on conjecture rather than substantial evidence. The CA's findings on AMC's liability were consistent with the trial court's findings, establishing AMC as the immediate and proximate cause of the allision.
Main Doctrine
The Supreme Court will not review facts in a petition for review on certiorari under Rule 45, as it is not a trier of facts. Factual questions are not the proper subject of such an appeal. Exceptions exist, such as when the factual findings of the Court of Appeals are contrary to those of the trial court, but only if the petitioner demonstrates manifest bias or extraordinary misperception of evidence by the CA.