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WILDVALLEY SHIPPING CO. v. CA

FACTS:

In February 1988, the vessel Philippine Roxas ran aground in the Orinoco River, obstructing the ingress and egress of vessels. Wildvalley Shipping Company, Ltd. filed a suit against Philippine President Lines, Inc. for damages. The trial court ruled in favor of Wildvalley Shipping, but the Court of Appeals reversed the decision, dismissing Wildvalley Shipping's complaint and ordering it to pay attorney's fees to Philippine President Lines, Inc. The petitioner filed a motion for reconsideration, which was denied. This petition for review on certiorari seeks to set aside the decision of the Court of Appeals.

The primary issue in the case is whether Venezuelan law should be applied. The court emphasized that foreign laws cannot be proven by themselves and should be proven in accordance with the rules of court. A photocopy of the Gaceta Oficial and a book published by the Ministerio de Comunicaciones of Venezuela were presented as evidence. However, the requisite certificate attesting that the documents were under the legal custody of the officer was not provided, rendering them inadmissible.

The presentation of evidence from Venezuela was insufficient due to the lack of proper authentication. Section 24 of Rule 132 of the Rules of Court requires a certificate attesting that the officer presenting the documents has legal custody of the records. In this case, the certificate was not provided and, therefore, the documents were not admissible.

ISSUES:

  1. Whether under Philippine law, fault or negligence can be attributed to the master or the owner of the M/V Philippine Roxas for the grounding of said vessel resulting in the blockage of the Orinoco River.

  2. Whether the “Philippine Roxas” is seaworthy.

  3. Whether the Venezuelan law should be applied and considered in the case.

  4. Whether the Court of Appeals erred in awarding attorney's fees and costs to the private respondent.

RULING:

  1. Fault or Negligence The Supreme Court ruled that the grounding of the vessel is attributable to the pilot, not the master or the owner of the M/V Philippine Roxas, as the pilot was responsible for navigating the channel.

  2. Seaworthiness The Court found that the M/V Philippine Roxas was seaworthy according to the evidence presented, including the testimony and documentation from the Lloyd's Register of Shipping and the successful navigation experience during the voyage.

  3. Application of Venezuelan Law The Court ruled that Venezuelan law was not properly pleaded and proved in the manner required by Philippine law, thus the case was to be adjudicated based on Philippine law under the principle of processual presumption.

  4. Attorney's Fees and Costs The awarding of attorney’s fees by the Court of Appeals was affirmed, considering it just and equitable since the private respondent was unjustifiably forced to litigate.

PRINCIPLES:

  • Processual Presumption In the absence of properly pleaded and proved foreign law, the forum’s domestic law will be applied.

  • Diligence of a Good Father of a Family The standard required in the absence of a specific contractual obligation, as per Article 1173 of the New Civil Code.

  • Burden of Proof for Foreign Law Foreign law must be alleged and proved with proper authentication to be given effect in Philippine courts.

  • Doctrine of Res Ipsa Loquitur Not applicable if the exclusive control over the instrumentality causing the injury is not with the defendant alone.

  • Seaworthiness Standard A vessel is seaworthy if it is reasonably fit for the intended voyage, even if not perfect.

  • Liability in Compulsory Pilotage The pilot is primarily responsible for navigational negligence in compulsory pilotage zones.

  • Attorney’s Fees May be awarded if a party is unjustifiably forced to litigate, under Article 2208 of the New Civil Code.