GR 160219; (July, 2008) (Digest)
G.R. No. 160219 ; July 21, 2008
Vector Shipping Corporation and Francisco Soriano, Petitioners, vs. Adelfo B. Macasa, et al., and Sulpicio Lines, Inc., et al., Respondents.
FACTS
On December 20, 1987, the passenger vessel MV Doña Paz, owned by Sulpicio Lines, collided with the oil tanker MT Vector, owned by Vector Shipping Corporation and Francisco Soriano, in the Tablas Strait. The collision resulted in the tragic loss of both vessels and the deaths of thousands, including spouses Cornelio and Anacleta Macasa and their grandson Ritchie. The victims’ heirs (the Macasas) filed a complaint for damages against Sulpicio Lines based on breach of contract of carriage.
Sulpicio Lines, in its defense, claimed it exercised extraordinary diligence and asserted that the collision was solely the fault of MT Vector. It cited the findings of the Board of Marine Inquiry (BMI), which exonerated it from liability. Sulpicio Lines subsequently filed a third-party complaint against Vector Shipping and Soriano. The Regional Trial Court ruled in favor of the Macasas, holding Sulpicio Lines liable and, in turn, holding Vector Shipping and Soriano solidarily liable to indemnify Sulpicio Lines.
ISSUE
The core issue is whether the Court of Appeals erred in affirming the lower court’s decision that held petitioners Vector Shipping and Soriano solely and solidarily liable for the damages arising from the collision.
RULING
The Supreme Court denied the petition and affirmed the CA decision with modification, holding Vector Shipping and Soriano solidarily liable with Sulpicio Lines to the Macasas. The Court clarified that the findings of the BMI, while not binding, are persuasive. The BMI report established that MT Vector was at fault for sailing with an expired license and certificate of inspection and being manned by an incompetent crew, making it unseaworthy. This constituted prima facie evidence of negligence.
The legal logic rests on the principle of res ipsa loquitur. The collision itself, given the circumstances, speaks of negligence attributable to the operators of both vessels. While Sulpicio Lines, as a common carrier, is presumed negligent under Article 1735 of the Civil Code, the evidence conclusively shows that MT Vector’s extreme negligence was the direct and proximate cause of the disaster. However, this does not absolve Sulpicio Lines from its contractual obligation to its passengers. Consequently, both shipping companies are joint tortfeasors. The Macasas, as claimants, have the right to recover damages from either carrier. The final ruling imposes solidary liability on both Vector Shipping/Soriano and Sulpicio Lines to pay the awarded damages to the Macasas, with the right of reimbursement between them to be determined in a separate proceeding.