GR 119602; (October, 2000) (Digest)
G.R. No. 119602 ; October 6, 2000
Wildvalley Shipping Co., Ltd., petitioner, vs. Court of Appeals and Philippine President Lines Inc., respondents.
FACTS
On February 12, 1988, the vessel M/V Philippine Roxas, owned by Philippine President Lines Inc. (PPL), ran aground in the compulsory pilotage waters of the Orinoco River in Puerto Ordaz, Venezuela. The grounding was under the conduct of a compulsory Venezuelan government pilot, Ezzar del Valle Solarzano Vasquez. The obstruction prevented the vessel M/V Malandrinon, owned by Wildvalley Shipping Co., Ltd., from sailing out of port, causing it alleged financial losses.
Wildvalley filed a complaint for damages against PPL before the Regional Trial Court of Manila, claiming negligence on the part of the Philippine Roxas’s captain and owner. The trial court ruled in favor of Wildvalley, awarding substantial damages. PPL appealed, and the Court of Appeals reversed the trial court’s decision, dismissing the complaint and awarding attorney’s fees to PPL.
ISSUE
Whether Philippine President Lines Inc., as shipowner, can be held liable for damages arising from the grounding of its vessel, which occurred under the control of a compulsory foreign pilot.
RULING
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, absolving PPL of liability. The legal logic rests on the established principle in maritime law that a shipowner is generally not liable for damages caused by the negligence of a compulsory pilot. The Court emphasized that pilotage in the Orinoco River was compulsory by Venezuelan authority; the pilot, not the ship’s master, had exclusive control over the vessel’s navigation at the time of the incident. The master’s presence on the bridge did not negate the pilot’s command, and there was no evidence presented that the master could have overridden the pilot’s orders to prevent the grounding.
The Court further found that the vessel was seaworthy and that the grounding was solely attributable to the pilot’s error in navigation. The petitioner’s attempt to invoke Venezuelan law was unavailing, as it was not properly pleaded and proved with the requisite official publication or authentication. Consequently, no fault or negligence could be imputed to the shipowner under the applicable Philippine maritime law. The award of attorney’s fees to PPL was sustained as the latter was compelled to litigate to defend against an unfounded claim.