GR 108397; (June, 2000) (Digest)
G.R. No. 108397 ; June 21, 2000
Food Terminal Incorporated, petitioner, vs. Court of Appeals and Basic Foods Corporation, respondents.
FACTS
Basic Foods Corporation, engaged in manufacturing food products, deposited 1,770 cartons of Red Star compressed yeast for cold storage with Food Terminal Incorporated (FTI) from June 10 to 23, 1987. The yeast required refrigerated storage to prevent spoilage. Basic Foods alleged that due to FTI’s negligence, specifically its failure to properly control the temperature in its warehouse, 383.6 cartons of yeast worth P161,112.00 were spoiled. After a futile demand for payment, Basic Foods filed a complaint for damages.
FTI denied the full quantity deposited and asserted it exercised the diligence of a good father of a family in caring for the goods. It contended that the cold storage contract exempted it from liability for losses due to causes beyond its reasonable control, including temperature variations or inherent defects in the goods. FTI also claimed Basic Foods had discretion in arranging the stocks and was estopped by its acknowledgment of receiving the goods in good condition. The Regional Trial Court dismissed the complaint.
ISSUE
Whether the Court of Appeals erred in ruling that FTI was negligent in the care and custody of Basic Foods’ goods, making it liable for damages.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. Firstly, the issue is factual, and findings of the Court of Appeals are generally conclusive and binding in a petition for review on certiorari. Secondly, and more substantively, FTI practically admitted its failure to maintain the contractually agreed storage temperature of 2 to 4 degrees centigrade at all times, which was established as the cause of the yeast’s deterioration.
While FTI argued that temperature was not the sole cause, the Court found that negligence on its part as a warehouseman had been established. Under the Civil Code, a party responsible for negligence in the performance of an obligation is liable for damages. The contractual stipulations purporting to exempt FTI from liability could not absolve it from the consequences of its own proven fault. Consequently, FTI’s liability for the value of the spoiled goods was inescapable.