GR 144439; (October, 2003) (Digest)
G.R. No. 144439; October 24, 2003
SOUTHEAST ASIA SHIPPING CORPORATION, petitioner, vs. SEAGULL MARITIME CORP. and COURT OF APPEALS, respondents.
FACTS
Seaman Nerry Balatongan, recruited by Philimare Shipping for Turtle Bay Shipping, suffered a permanent disability from a 1983 accident. The Supreme Court, in a final 1989 decision (G.R. No. 82252), held the employer and its subsequent manning agent, Seagull Maritime Corp., solidarily liable for his $50,000 insurance claim due to their failure to assist in its timely filing. To execute this judgment, Seagull paid Balatongan and then sought reimbursement from Southeast Asia Shipping Corp. (SEASCORP).
Seagull’s claim was based on an Affidavit of Undertaking executed by SEASCORP’s president in 1987 during its POEA accreditation as a new manning agent for Navales (acting for Arawa Bay Shipping). The affidavit stated SEASCORP “assumes full and complete responsibility over all seamen/workers originally recruited and deployed by SEAGULL for NAVALES.” The trial court and Court of Appeals ruled this affidavit made SEASCORP solidarily liable for Seagull’s obligations, including the judgment debt to Balatongan.
ISSUE
Whether the Affidavit of Undertaking executed by SEASCORP renders it solidarily liable for the judgment obligation of Seagull Maritime Corp. to Nerry Balatongan.
RULING
No. The Supreme Court reversed the Court of Appeals, ruling that SEASCORP is not liable. The legal logic centers on the proper interpretation of the Affidavit of Undertaking. While the affidavit’s literal wording suggests a broad assumption of Seagull’s liabilities, the Court applied Rule 130, Section 13 of the Rules of Court, which mandates that for proper construction, the circumstances under which an instrument was made must be considered to ascertain the parties’ true intention.
Examining the contemporaneous documents—the Manning Agency Agreement and the Special Power of Attorney between Navales and SEASCORP—reveals the affidavit’s context. These documents unequivocally state that Navales was acting “for and on behalf of Arawa Bay Shipping” when appointing SEASCORP. In contrast, the liability to Balatongan originated from Navales acting for a different principal, Turtle Bay Shipping, under prior agreements with Philimare and Seagull. The affidavit, likely copied from a POEA form, was a mistake that did not reflect the true agreement, which was limited to responsibilities for Arawa Bay Shipping’s operations. To enforce the literal reading would unjustly impose a liability SEASCORP never intended to assume for a principal (Turtle Bay) it never represented. Therefore, the complaint for reimbursement was dismissed.