GR L 24264; (May, 1968) (Digest)
G.R. No. L-24264 May 4, 1968
PHILIPPINE EDUCATION CO., plaintiff-appellee, vs. MANILA PORT SERVICE AND MANILA RAILROAD COMPANY, defendants-appellants.
FACTS
The facts were stipulated. The Manila Port Service, as arrastre operator, short-delivered twelve (12) cartons of books and magazines belonging to the Philippine Education Co. The value of the importation was not specified or manifested in the shipping manifest or Bill of Lading, and arrastre charges were paid based on measurement and weight, not on value. It was stipulated that out of 319 cartons, only 307 were delivered. The total CIF value of the 12 undelivered cartons was P548.06, and the total invoice value was P383.90. The management contract between the parties limited the arrastre operator’s liability to the invoice value of each package, but not more than P500.00 per package, unless the value was otherwise specified/manifested and corresponding arrastre charges had been paid.
ISSUE
Whether the liability of the defendants-appellants (Manila Port Service and Manila Railroad Company) for the short-delivered goods should be limited to the stipulated invoice value of P383.90, or to the maximum amount of P500.00 per package as stated in the management contract.
RULING
The Supreme Court modified the lower court’s decision. The liability of the defendants is governed by the specific terms of the management contract, which was binding on the parties. The contract stipulated payment of the “invoice value of each package but which in no case shall be more than five hundred pesos (P500.00) for each package” unless the value was manifested and extra charges paid. Since the parties stipulated that the total invoice value of the 12 cartons was P383.90, the lower court was bound by this stipulation of facts and could not impose a different and greater sum. Therefore, the defendants’ liability is limited to the invoice value of P383.90, not the maximum contractual limit of P500.00. The defendants were ordered to pay plaintiff, jointly and severally, the amount of P383.90 with legal interest from the filing of the complaint.