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SULPICIO LINES v. NAPOLEON SESANTE

FACTS:

This case involves the sinking of the M/V Princess of the Orient, a passenger vessel owned and operated by petitioner Sulpicio Lines, Inc. The vessel sank near Fortune Island in Batangas, resulting in the loss of 150 passengers. The survivor, Napoleon Sesante, a member of the Philippine National Police, filed a complaint against the petitioner for breach of contract and damages. Sesante alleged that the vessel sailed despite stormy weather, causing panic among the passengers, hunger, thirst, pain, fear, shock, anxiety, and mental anguish. He also suffered injuries and lost personal belongings. The Regional Trial Court ruled in favor of Sesante and ordered the petitioner to pay temperate and moral damages. The petitioner appealed to the Court of Appeals, which affirmed the RTC's decision with modification, reducing the amount of temperate damages. The petitioner then appealed to the Supreme Court, alleging errors on the part of the Court of Appeals.

In another case involving the sinking of the M/V Princess of the Orient, the deceased plaintiff, Sesante, had filed an action for breach of contract and damages against petitioner Sulpicio Sans, a common carrier. Sesante passed away during the pendency of the case, and the issue arose as to whether the complaint for damages is a personal action that does not survive his death. The court was also tasked to determine whether the petitioner is liable for damages under Article 1759 of the Civil Code, and if there is sufficient basis for awarding moral and temperate damages.

The sinking of the M/V Princess of the Orient was caused by a fortuitous event, specifically a severe storm. The common carrier, Magsaysay Maritime Corporation, argued that it should be relieved of liability because the sinking was caused by a force majeure and that the vessel was seaworthy. However, the report by the Board of Marine Inquiry contradicted this claim, as it found that the sinking was primarily caused by the captain's erroneous maneuvers. The BMI concluded that the captain's gross negligence was the immediate and proximate cause of the accident. The court held that even if the vessel was seaworthy, the petitioner could not escape liability because the sinking was primarily caused by human intervention.

On another complaint filed against Sulpicio Lines, the court found that the sinking of the M/V Princess of the Orient was due to the gross negligence of the vessel's captain in maneuvering the vessel. It was noted that the sinking occurred while Metro Manila was experiencing Storm Signal No. 1. The Board of Marine Inquiry determined that a vessel like the M/V Princess of the Orient should have been capable of withstanding Storm Signal No. 1. The survivors and heirs of the victims filed a complaint for damages against Sulpicio Lines, alleging negligence and fault on the part of the captain and crew of the vessel.

ISSUES:

  1. Whether the sinking of the ship was caused by the gross negligence of its captain

  2. Whether the award of moral damages and temperate damages is proper

  3. Whether the crew of M/V Princess of the Orient is liable for moral damages.

  4. Whether the common carrier is liable for the loss of the passenger's personal belongings.

  5. Whether the hotelkeeper can be held liable for the loss of personal belongings of a guest even without actual delivery of the goods.

  6. Whether temperate damages were properly awarded.

  7. Whether the hotelkeeper should be held liable for exemplary damages.

  8. Whether the petitioner and its agents acted wantonly and recklessly during the incident.

  9. Whether the award of exemplary damages in the amount of P1,000,000.00 is proper.

  10. The main issue in this case is whether or not the petitioner is liable for damages for the death of Napoleon Sesante.

RULING:

  1. Yes, the sinking of the ship was caused by the gross negligence of its captain. The Board of Marine Inquiry found that the immediate and proximate cause of the sinking was the erroneous maneuvering command of the captain. It was also established that the crew of the ship was negligent in manning it.

  2. The award of moral damages and temperate damages is proper. While moral damages may only be recovered in an action for breach of contract of carriage if death results or if the carrier was guilty of fraud and bad faith, moral damages may also be awarded if the contractual breach is found to be wanton and deliberately injurious, or if the one responsible acted fraudulently or with malice or bad faith. In this case, the negligent acts of the officers and crew of the ship were found to be wanton and deliberately injurious.

  3. Yes, the crew of M/V Princess of the Orient is liable for moral damages. The totality of the negligence by the officers and crew of the vessel, coupled with the petitioner's seeming indifference to render assistance to the passenger, warranted the award of moral damages. The Court recognized the mental anguish, agony, and pain suffered by the passenger who fought to survive in the midst of the raging waves of the sea. The amount of P1,000,000.00 granted by the trial court and affirmed by the CA is maintained.

  4. Yes, the common carrier is liable for the loss of the passenger's personal belongings. The law requires the common carrier to observe the same diligence as hotel keepers in case the baggage remains with the passenger; otherwise, extraordinary diligence must be exercised. The liability of the common carrier attaches even if the loss or damage to the belongings resulted from the acts of its employees, except when such loss or damages is due to force majeure. Notification is not required before the common carrier becomes liable for lost belongings that remained in the custody of the passenger.

  5. The hotelkeeper can be held liable for the loss of personal belongings of a guest even without actual delivery of the goods. The hotelkeeper shall remain accountable for the personal effects brought inside the hotel or inn. Actual notification is not necessary to render the hotelkeeper liable and ensuring the safety of the belongings during the voyage is the hotelkeeper's duty as a common carrier.

  6. Temperate damages were properly awarded. The court can award temperate damages when there is some pecuniary loss but the amount cannot be proven with certainty. The value of the lost belongings approximated the costs of the lost belongings, thus the award of temperate damages is correct.

  7. The hotelkeeper should be held liable for exemplary damages. Exemplary damages can be awarded if the defendant acted in a wanton, fraudulent, reckless, oppressive, or malevolent manner. The court has the discretion to award exemplary damages and it is not necessary for them to be specifically pleaded or proved.

  8. Yes, the petitioner and its agents acted wantonly and recklessly during the incident. The acts of the captain in failing to exercise prudence, failing to reduce the speed of the vessel, and executing several maneuvers that added to the tilting of the vessel all demonstrated extreme recklessness and utter disregard for the rights of others. Their conduct was an extreme departure from ordinary care, in a situation where a high degree of danger was apparent.

  9. Yes, the award of exemplary damages in the amount of P1,000,000.00 is proper. The purpose of exemplary damages is to serve as a deterrent to serious wrongdoings and as a vindication of undue sufferings and wanton invasion of rights. In awarding exemplary damages, the court sought to exemplify the need for greater vigilance in the conduct of a business imbued with public interest. The amount of P1,000,000.00 was considered appropriate and not excessive.

  10. The Supreme Court ruled in favor of the respondent and affirmed the decision of the lower court with modifications. The petitioner was held liable for damages for the death of Napoleon Sesante. The court fixed the amount of moral damages at P1,000,000.00, granted P1,000,000.00 as exemplary damages, and allowed the sum of P120,000.00 as temperate damages, all to be paid to the heirs of the late Napoleon Sesante. The awarded amounts shall also earn interest of 6% per annum from the finality of the decision until fully paid. Additionally, the petitioner was ordered to pay the costs of suit.

PRINCIPLES:

  • A common carrier may be held liable for the sinking of a ship caused by the gross negligence of its captain.

  • Moral damages may be awarded in an action for breach of contract of carriage if death results or if the carrier was guilty of fraud and bad faith, but may also be awarded if the contractual breach is found to be wanton and deliberately injurious, or if the one responsible acted fraudulently or with malice or bad faith.

  • The common carrier is always responsible for the passenger's baggage during the voyage.

  • The common carrier must observe the same diligence as hotel keepers in case the baggage remains with the passenger; otherwise, extraordinary diligence must be exercised.

  • The liability of the common carrier attaches even if the loss or damage to the belongings resulted from the acts of its employees, except when such loss or damages is due to force majeure.

  • Notification is not required before the common carrier becomes liable for lost belongings that remained in the custody of the passenger.

  • Hotelkeepers are accountable for the personal effects brought inside the hotel or inn.

  • Actual notification is not necessary to hold a hotelkeeper or common carrier liable for loss or damages of personal belongings of guests.

  • Temperate damages can be awarded when some pecuniary loss has been suffered but the amount cannot be proven with certainty.

  • Exemplary damages can be awarded in contracts and quasi-contracts if the defendant acted in a wanton, fraudulent, reckless, oppressive, or malevolent manner. The court has discretion in awarding exemplary damages and it is not necessary to specifically plead or prove them.

  • Exemplary or corrective damages are intended to serve as a deterrent to serious wrongdoings and as a vindication of undue sufferings and wanton invasion of rights.

  • Exemplary damages may be awarded against a person to punish him for his outrageous conduct.

  • Exemplary damages are intended to deter the wrongdoer and others like him from similar conduct in the future.

  • Wanton and reckless conduct is characterized by extreme recklessness and utter disregard for the rights of others.

  • Reckless conduct is an extreme departure from ordinary care in a situation where a high degree of danger is apparent.

  • Exemplary damages should be awarded to instill in the defendant and others similarly situated the need for greater vigilance in conducting a business imbued with public interest.

  • Liability for damages arising from wrongful death - The case recognizes the principle that a person can be held liable for damages for the death of another person, and the affected party is entitled to recover moral damages, exemplary damages, and temperate damages.

  • Computation of damages - The decision provides guidance on how damages should be computed, with the court fixing the amount for moral damages, exemplary damages, and temperate damages based on the circumstances of the case and the losses suffered by the affected party.

  • Accrued interest on damages - The court established the principle that awarded damages shall earn interest from the finality of the decision until fully paid, ensuring that the affected party is fully compensated for their losses.