G.R. No.
193986, January 15, 2014
EASTERN SHIPPING LINES INC., Petitioner, vs. BPI/MS INSURANCE CORP.
and MITSUI SUM TOMO INSURANCE CO. LTD., Respondents.
VILLARAMA, JR., J.
DOCTRINE: Negligence in handling goods can result in liability for damages. Insurers
and subrogees have the right to seek damages from negligent parties.
FACTS: Eastern Shipping Lines, Inc. (ESLI) transported steel products from Korea to
the Philippines under a bill of lading issued for the consignee. Upon arrival, the cargo
was damaged. The consignee was indemnified by BPI/MS Insurance Corporation, which
was subrogated to the consignee's rights. BPI/MS filed a case against ESLI to recover the
amount paid, alleging negligence on ESLI's part. ESLI claimed the damage was due to
improper packaging, exempting it from liability under the Civil Code.
RTC found both Eastern Shipping Lines and ATI jointly and severally liable for the
damages, citing their negligence in handling the cargo. CA affirmed with modification,
removing the award of attorney's fees for lack of justification.
Hence, in this instant petition.
ISSUE. Whether the CA erred in affirming the findings of the RTC?
RULING: 1. No, the Court of Appeals (CA) did not err in affirming the findings of the
Regional Trial Court (RTC).
The CA found no reversible error in the RTC's decision, which means that the RTC's
findings were supported by substantial evidence and in accordance with the law.
The RTC found that both Eastern Shipping Lines and Asian Terminals, Inc. (ATI) were
negligent in handling the cargo, causing damage to the steel coils. This finding was based
on substantial evidence, including inspection reports and photographs showing the
damaged condition of the coils upon arrival.
The CA reviewed the evidence and the legal principles applied by the RTC and
concluded that the trial court had correctly held both parties liable. The CA's role is to
ensure that the RTC's findings are supported by evidence and that there are no legal
errors in the decision. In this case, the CA determined that the RTC's findings were
correct and that the decision was in accordance with the law.
The Supreme Court affirmed the decision of the Court of Appeals (CA) and upheld the
findings of the Regional Trial Court (RTC). The SC ruled that both Eastern Shipping
Lines, Inc. and Asian Terminals, Inc. (ATI) were negligent in handling the cargoes,
which resulted in damages. The SC agreed with the lower courts that the evidence
presented was sufficient to establish negligence on the part of both parties1.
WHEREFORE, the petition is DENIED. The Decision dated July 9, 2010 of the Court of
Appeals in CA-G.R. CV No. 88361 is hereby AFFIRMED.
With costs against the petitioner. SO, ORDERED.
