Tag: Limited Liability Rule

Maritime Law: Shipowner’s Liability and Seafarer’s Death Benefits – Understanding Insurance and Solidary Obligations

In a maritime dispute concerning the sinking of a vessel and the subsequent death of seafarers, the Supreme Court clarified the interplay between a shipowner’s liability, insurance policies, and solidary obligations under the Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC). The Court ruled that the doctrine of limited liability does not apply to claims for death benefits under the POEA-SEC. However, a settlement reached with some of the parties who share responsibility for the obligation can reduce the overall amount owed. This means that while shipowners cannot escape their obligations to seafarers through the limited liability rule, settlements with other responsible parties can decrease their financial burden.

Sinking Ships and Shifting Liabilities: Who Pays When Seafarers Perish at Sea?

This case arose from the tragic sinking of the MV Mahlia in 2003, resulting in the death of several crewmembers. The heirs of the deceased seafarers filed claims for death benefits against Phil-Nippon Kyoei, Corp. (the shipowner), Top Ever Marine Management Maritime Co., Ltd. (TMCL, the foreign principal), Top Ever Marine Management Philippine Corporation (TEMMPC, the local manning agency), Capt. Oscar Orbeta, and South Sea Surety & Insurance Co., Inc. (SSSICI, the insurer). The central legal question revolved around determining the extent of each party’s liability, considering the shipowner’s insurance coverage and the principle of limited liability in maritime law.

The Labor Arbiter (LA) initially found all parties solidarily liable, including SSSICI for the proceeds of the Personal Accident Policies. The National Labor Relations Commission (NLRC) later absolved the shipowner, TMCL, TEMMPC and Capt. Orbeta, citing the limited liability rule. However, the Court of Appeals (CA) reinstated the LA’s decision, finding the shipowner and manning agency liable. The CA further ruled that the shipowner’s liability would be extinguished only upon SSSICI’s payment of the insurance proceeds. This ruling prompted the shipowner to file a petition with the Supreme Court, challenging the CA’s decision.

The Supreme Court addressed two key issues. First, whether the doctrine of real and hypothecary nature of maritime law (the limited liability rule) applies in favor of the shipowner. Second, whether the CA erred in ruling that the shipowner’s liability is extinguished only upon SSSICI’s payment of insurance proceeds. The Court clarified that the shipowner was a local principal and as such, it is solidarily liable with TEMMPC and TMCL for the benefits under the POEA-SEC. The Court emphasized that the limited liability rule, which generally limits a shipowner’s liability to the value of the vessel and freightage, does not apply to claims arising from the POEA-SEC.

Art. 587. The ship agent shall also be civilly liable for the indemnities in favor of third persons which arise from the conduct of the captain in the care of the goods which the vessel carried; but he may exempt himself therefrom by abandoning the vessel with all her equipment and the freightage he may have earned during the voyage.

Art. 590. The co-owners of a vessel shall be civilly liable, in the proportion of their contribution to the common fund, for the results of the acts of the captain, referred to in Art. 587.

Each part-owner may exempt himself from this liability by the abandonment before a notary of the part of the vessel belonging to him.

Art. 837. The civil liability incurred by the shipowners in the cases prescribed in this section, shall be understood as limited to the value of the vessel with all its appurtenances and freightage earned during the voyage.

The Court explained that this rule, derived from Articles 587, 590, and 837 of the Code of Commerce, aims to encourage maritime commerce by limiting the financial exposure of shipowners. However, it is not absolute. The Supreme Court has consistently held that the limited liability rule does not apply to workmen’s compensation claims or, by extension, to claims for death benefits under the POEA-SEC.

The real and hypothecary nature of the liability of the shipowner or agent embodied in the provisions of the Maritime Law, Book III, Code of Commerce, had its origin in the prevailing conditions of the maritime trade and sea voyages during the medieval ages, attended by innumerable hazards and perils. To offset against these adverse conditions and to encourage shipbuilding and maritime commerce, it was deemed necessary to confine the liability of the owner or agent arising from the operation of a ship to the vessel, equipment, and freight, or insurance, if any, so that if the shipowner or agent abandoned the ship, equipment, and freight, his liability was extinguished.

But the provisions of the Code of Commerce invoked by appellant have no room in the application of the Workmen’s Compensation Act which seeks to improve, and aims at the amelioration of, the condition of laborers and employees. It is not the liability for the damage or loss of the cargo or injury to, or death of, a passenger by or through the misconduct of the captain or master of the ship; nor the liability for the loss of the ship as a result of collision; nor the responsibility for wages of the crew, but a liability created by a statute to compensate employees and laborers in cases of injury received by or inflicted upon them, while engaged in the performance of their work or employment, or the heirs and dependents of such laborers and employees in the event of death caused by their employment. Such compensation has nothing to do with the provisions of the Code of Commerce regarding maritime commerce. It is an item in the cost of production which must be included in the budget of any well-managed industry.

The Court reasoned that death benefits under the POEA-SEC are akin to workmen’s compensation claims, designed to protect seafarers and their families in the event of work-related death or injury. These benefits are separate and distinct from those under the Maritime Law.

However, the Court also considered the impact of the Release and Quitclaim executed between the respondents and TEMMPC, TMCL, and Capt. Oscar Orbeta. Since the shipowner was solidarily liable with these parties, the Court held that the settlement redounded to the shipowner’s benefit, effectively reducing its liability. The Court emphasized that the basis of the solidary liability of the principal with the local manning agent is found in the second paragraph of Section 10 of the Migrant Workers and Overseas Filipino Act of 1995, which, in part, provides: “[t]he liability of the principal/employer and the recruitment/placement agency for any and all claims under this section shall be joint and several.”

Art. 1217. Payment made by one of the solidary debtors extinguishes the obligation. If two or more solidary debtors offer to pay, the creditor may choose which offer to accept. xxx

Art. 1222. A solidary debtor may, in actions filed by the creditor, avail himself of all defenses which are derived from the nature of the obligation and of those which are personal to him, or pertain to his own share. With respect to those which personally belong to the others, he may avail himself thereof only as regards that part of the debt for which the latter are responsible.

Regarding the insurance policies, the Court affirmed the NLRC’s jurisdiction over the claim, stating that it arose from an employer-employee relationship and involved Filipino workers for overseas deployment. However, the Court clarified that the Personal Accident Policies were indemnity insurance procured by the shipowner for the benefit of the seafarers, not liability insurance to protect the shipowner from its own liabilities.

The Court found the insurer’s liability direct. SSSICI, as insurer, undertook to indemnify the crewmembers’ beneficiaries from an unknown or contingent event. Therefore, the CA erred in making the shipowner’s liability conditional on SSSICI’s payment of the insurance proceeds. In a liability insurance, the insurer assumes the obligation to pay third party in whose favor the liability of the insured arises. On the other hand, personal accident insurance refers to insurance against death or injury by accident or accidental means.

FAQs

What was the key issue in this case?	The key issue was determining the extent of the shipowner’s liability for the death of seafarers, considering the limited liability rule, the POEA-SEC, and the existence of insurance policies.
Does the limited liability rule apply to claims for death benefits under the POEA-SEC?	No, the Supreme Court held that the limited liability rule does not apply to claims arising from the POEA-SEC, which provides for death benefits for seafarers.
What is solidary liability?	Solidary liability means that each debtor is responsible for the entire debt. The creditor can demand payment of the entire obligation from any one of the solidary debtors.
How did the settlement with the manning agency affect the shipowner’s liability?	Since the shipowner was solidarily liable with the manning agency, the settlement redounded to the shipowner’s benefit, reducing its overall liability.
What type of insurance policies were involved in this case?	The case involved a marine insurance policy on the vessel and personal accident policies for the crewmembers.
Who is directly liable under the personal accident policies?	The insurer, SSSICI, is directly liable to the beneficiaries of the seafarers under the personal accident policies.
Was the shipowner directly liable under the personal accident policies?	No, the shipowner was the policyholder, not the insurer, and therefore not directly liable for the proceeds of the personal accident policies.
What is the POEA-SEC?	The POEA-SEC refers to the Philippine Overseas Employment Administration Standard Employment Contract, setting minimum terms and conditions for Filipino seafarers’ employment.

In conclusion, the Supreme Court’s decision clarifies the responsibilities of shipowners, manning agencies, and insurers in cases involving the death of seafarers. This ruling emphasizes the importance of understanding the interplay between maritime law, labor contracts, and insurance policies to ensure that seafarers and their families receive the compensation and benefits they are entitled to under the law.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PHIL-NIPPON KYOEI, CORP. VS. ROSALIA T. GUDELOSAO, G.R. No. 181375, July 13, 2016

July 13, 2016

Liability in Maritime Charters: Who Pays When the Ship Goes Down?

In Agustin P. Dela Torre v. Court of Appeals, the Supreme Court addressed liability issues arising from a vessel sinking under a complex web of charter agreements. The Court ruled that the actual shipowner could recover damages from the charterer and sub-charterer due to their negligence and failure to insure the vessel, reinforcing contractual obligations within maritime law. This decision highlights the importance of clear contractual terms and due diligence in maritime operations, clarifying who bears responsibility when a chartered vessel is lost due to negligence.

When a Charter Turns Catastrophe: Tracing Liability for a Sunken Vessel

This case involves a chain of agreements concerning the LCT-Josephine, a vessel owned by respondent Crisostomo G. Concepcion. Concepcion initially entered a “Preliminary Agreement” with Roland de la Torre for dry-docking, repairs, and subsequent charter. Following this, Concepcion and Philippine Trigon Shipyard Corporation (PTSC), represented by Roland, formalized a charter agreement. Subsequently, PTSC sub-chartered the vessel to Trigon Shipping Lines (TSL), owned by Agustin de la Torre. Finally, TSL sub-chartered the LCT-Josephine to Ramon Larrazabal for transporting cargo.

On November 23, 1984, the vessel, laden with sand and gravel, arrived in Leyte. During unloading, the vessel’s ramp malfunctioned, causing it to tilt and take on water, ultimately leading to its sinking. Concepcion sought damages, leading to a legal battle involving PTSC, Roland, Agustin, and Larrazabal. The central legal question is determining which parties are liable for the loss of the vessel, considering the multiple layers of charter agreements and the alleged negligence in the vessel’s operation.

The Regional Trial Court (RTC), and later the Court of Appeals (CA), found PTSC, Roland, and Agustin jointly and severally liable for the loss. Agustin and PTSC challenged these findings, leading to the consolidated petitions before the Supreme Court. The petitioners argued that the Limited Liability Rule under the Code of Commerce should apply and that the lower courts erred in their factual findings and application of the law. The Supreme Court ultimately upheld the CA’s decision, reinforcing the liability of the charterer and sub-charterer.

The Supreme Court affirmed the factual findings of the lower courts, which established that the sinking was due to the improper lowering of the vessel’s ramp, a responsibility falling under the charterer’s control. The Court emphasized that factual findings of the trial court, especially when affirmed by the appellate court, are binding. The CA noted that the crew manning the vessel belonged to TSL/Agustin and that the problem arose during docking operations, not directly from Larrazabal’s actions. This effectively placed the blame on the operational management of the vessel under the sub-charterer.

The petitioners’ reliance on the Limited Liability Rule under the Code of Commerce was deemed misplaced. The Supreme Court clarified that this rule, designed to encourage investment in maritime commerce, limits a shipowner’s liability to the value of the vessel. The Court cited Article 587 of the Code of Commerce, which pertains to indemnities in favor of third persons arising from the captain’s conduct in the care of goods. The Court stated the Limited Liability Rule protects the shipowner, in this case, Concepcion, and cannot be invoked by the charterers to escape liability for their negligence. In Yangco v. Laserna, the Court explained the policy behind the rule:

The policy which the rule is designed to promote is the encouragement of shipbuilding and investment in maritime commerce.

The Supreme Court further distinguished between the rights and responsibilities of shipowners and charterers, referencing Yueng Sheng Exchange and Trading Co. v. Urrutia & Co., which stated a charterer does not assume all the responsibilities of the shipowner. It emphasized that even in a bareboat charter, the dominion over the vessel remains with the shipowner. Therefore, the charterer or sub-charterer cannot invoke the Limited Liability Rule against the vessel’s owner.

Turning to the liability of the charterer and sub-charterer, the Court determined that the agreements constituted private carriage. Given the exclusive control and use of the vessel by the charterer and sub-charterer, they were considered the vessel’s owners pro hac vice. Since the Code of Commerce lacks specific provisions governing the rights and obligations between the shipowner and charterer in this scenario, the Court turned to the New Civil Code to fill the gap.

Under the New Civil Code, Roland was held liable under Article 1189 due to his initial agreement with Concepcion and his failure to return the vessel after repairs. PTSC, as the charterer, was liable under Articles 1665 and 1667 for the loss of the vessel. Agustin, as the sub-charterer, was liable under Article 1651 for failing to preserve the chartered vessel. Even though Agustin was not initially included in Concepcion’s complaint, the Court deemed the complaint amended to include him since he had the opportunity to defend himself in court. As the Court stated in Balquidra v. CFI of Capiz, Branch II:

(S)ince the purpose of formally impleading a party is to assure him a day in court, once the protective mantle of due process of law has in fact been accorded a litigant, whatever the imperfection in form, the real litigant may be held liable as a party.

Additionally, all three petitioners were held liable under Article 1170 for contravening the terms of their agreements by failing to insure the LCT-Josephine, despite explicit requirements in their contracts. The Court emphasized the clear obligation to insure the vessel, highlighting Concepcion’s repeated inquiries about the insurance coverage as evidence of its importance.

FAQs

What was the key issue in this case?	The central issue was determining which parties were liable for the loss of a vessel that sank while under a sub-charter agreement, considering the chain of contracts and alleged negligence.
What is the Limited Liability Rule?	The Limited Liability Rule, under the Code of Commerce, limits a shipowner’s liability to the value of the vessel to encourage investment in maritime commerce. This rule generally applies to claims by third parties related to the conduct of the captain.
Can a charterer invoke the Limited Liability Rule against the shipowner?	No, the Supreme Court clarified that the Limited Liability Rule is designed to protect the shipowner and cannot be used by a charterer to avoid liability for their own negligence or contractual breaches.
What is a private carriage?	A private carriage occurs when a vessel is chartered for the exclusive use of a specific party, and its services are not offered commercially to the general public. In such cases, the rights and obligations are governed primarily by the charter agreement.
What is the liability of a sub-charterer?	A sub-charterer is bound to the original lessor for all acts related to the use and preservation of the leased property, according to the terms stipulated between the lessor and the lessee. They are responsible for maintaining the vessel as agreed in the original charter.
What is the effect of failing to insure a vessel as contractually agreed?	Failing to insure a vessel, as required by contract, constitutes a breach of obligation, making the responsible parties liable for damages resulting from the loss of the vessel. This includes the vessel’s value and other consequential losses.
Why was Agustin de la Torre held liable even though he wasn’t initially in the complaint?	Agustin was included as a third-party defendant and had the opportunity to defend himself in court. The court deemed the complaint amended to include him to ensure a fair trial.
What Civil Code articles were used to determine liability?	Articles 1170 (breach of obligation), 1189 (loss of a specific thing), 1651 (obligations of a sublessee), 1665 (return of leased property), and 1667 (responsibility for loss of leased property) of the New Civil Code were applied.

The Dela Torre v. Court of Appeals case underscores the importance of clearly defined contractual responsibilities and the necessity of fulfilling obligations, particularly in maritime agreements. This ruling serves as a reminder for charterers and sub-charterers to exercise due diligence in managing chartered vessels and to comply with all contractual stipulations, including insurance requirements. By clarifying these liabilities, the Supreme Court reinforced the significance of contractual obligations in maritime law.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Agustin P. Dela Torre, G.R. No. 160088, July 13, 2011

July 13, 2011

Finality of Judgments: Upholding the Integrity of Court Decisions

The Supreme Court affirmed the importance of final and executory judgments, preventing parties from re-litigating decided issues. This decision reinforces the principle that once a court ruling becomes final, it must be enforced, ensuring justice and preventing endless legal battles. This ruling underscores the necessity of respecting final court decisions and adhering to the legal process, preventing parties from undermining judicial authority.

When Sinking Ships Can’t Sink Final Judgments: A Case of Maritime Law and Legal Endings

This case involves a shipping dispute that reached the Supreme Court, highlighting the legal principle of finality of judgments. Seven Brothers Shipping Corporation sought to overturn a Court of Appeals decision holding them liable for the loss of cargo due to the sinking of their vessel, M/V “Diamond Bear.” Oriental Assurance Corporation, as the insurer who paid the cargo’s value to the consignee, pursued the claim as a subrogee. The central legal question revolved around whether Seven Brothers could re-litigate issues already decided in a prior, final judgment.

The legal saga began with a charter party agreement between C. Alcantara & Sons, Inc. and Seven Brothers for the vessel M/V “Diamond Bear” to transport lauan logs. Oriental Assurance insured the cargo for P8,000,000.00. Unfortunately, the vessel sank off the coast of Mati, Davao Oriental, resulting in the total loss of the cargo. Oriental Assurance paid Alcantara & Sons the insured value and, as a subrogee, filed a complaint against Seven Brothers to recover the payment.

The Regional Trial Court (RTC) initially dismissed Oriental Assurance’s complaint, but the Court of Appeals reversed this decision, finding Seven Brothers liable due to the unseaworthiness of the vessel. The appellate court invoked Article 841 of the Code of Commerce, emphasizing that the sinking was not due to force majeure but to the carrier’s negligence. The Court of Appeals stated:

“If the wreck or stranding should arise through malice, negligence, or lack of skill of the captain, or because the vessel put to sea insufficiently repaired and supplied, the owner or the freighters may demand indemnity of the captain for the damages caused to the vessel or cargo by the accident, in accordance with the provisions contained in articles 610, 612, 614 and 621.”

Seven Brothers then filed a petition for review on certiorari with the Supreme Court, which was dismissed due to a technicality—lack of a certification of non-forum shopping. This dismissal made the Court of Appeals’ decision final and executory.

Following the finality of the judgment, Oriental Assurance sought a writ of execution from the RTC to enforce the judgment. However, Seven Brothers filed a motion to quash the writ, arguing that the levy on their vessels was invalid because one vessel was owned by another company and the sheriff did not properly demand payment before the levy. The RTC surprisingly granted Seven Brothers’ motion, leading Oriental Assurance to file a petition for certiorari with the Court of Appeals.

The Court of Appeals reversed the RTC’s order, holding that the trial court acted with grave abuse of discretion and lack of jurisdiction. The appellate court reinstated the writ of execution and the levy on Seven Brothers’ vessels. Dissatisfied, Seven Brothers elevated the case to the Supreme Court, raising issues related to the American Limited Liability Act and the propriety of the levy on their vessels.

The Supreme Court emphasized that the previous decision of the Court of Appeals, holding Seven Brothers liable for the loss of the cargo, had already become final and executory. As such, the Court reiterated the principle that once a judgment reaches finality, it is immutable and can no longer be modified or amended, except for clerical errors or to order its execution.

The Supreme Court cited the case of Lim vs. Jabalde, where the Court explained the necessity of adhering to the doctrine of immutability of final judgments:

“Litigation must end and terminate sometime and somewhere and it is essential to an effective and efficient administration of justice that, once a judgment has become final, the winning party be, not through a mere subterfuge, deprived of the fruits of the verdict. Courts must therefore guard against any scheme calculated to bring about that result. Constituted as they are to put an end to controversies, courts should frown upon any attempt to prolong them.”

The Court found Seven Brothers’ attempt to re-litigate issues already decided in the previous case unacceptable. It underscored that allowing such actions would undermine the stability and conclusiveness of judicial decisions. The Supreme Court also rejected Seven Brothers’ argument regarding the improper levy on their vessels, citing Section 9, Rule 39 of the 1997 Rules of Civil Procedure, which outlines the process for executing judgments for money:

“(a) Immediate payment on demand. – The officer shall enforce an execution of a judgment for money by demanding from the judgment obligor the immediate payment of the full amount stated in the writ of execution and all lawful fees. The judgment obligor shall pay in cash, certified bank check payable to the judgment obligee, or any other form of payment acceptable to the latter, the amount of the judgment debt under proper receipt directly to the judgment obligee or his authorized representative if present at the time of payment. The lawful fees shall be handed under proper receipt to the executing sheriff who shall turn over the said amount within the same day to the clerk of court of the court that issued the writ.

“(b) Satisfaction by levy. – If the judgment obligor cannot pay all or part of the obligation in cash, certified bank check or other mode of payment acceptable to the judgment obligee, the officer shall levy upon the properties of the judgment obligor of every kind and nature whatsoever which may be disposed of for value and not otherwise exempt from execution giving the latter the option to immediately choose which property or part thereof may be levied upon, sufficient to satisfy the judgment. If the judgment obligor does not exercise the option, the officer shall first levy on the personal properties, if any, and then on the real properties if the personal properties are insufficient to answer for the judgment. x x x”

The Court noted that Seven Brothers did not disprove the finding that its existing assets were insufficient to satisfy the judgment. Furthermore, Seven Brothers failed to post a cash bond or offer an acceptable alternative payment method. The Court referenced Torres vs. Cabling, emphasizing that a sheriff is not required to give the judgment debtor time to raise cash, especially when there is a risk of the property being lost or absconded.

The Supreme Court acknowledged the importance of procedural rules but emphasized that such rules should be interpreted liberally to facilitate the attainment of justice. The Court cited Cometa vs. Court of Appeals, stating that “since rules of procedure are mere tools designed to facilitate the attainment of justice, their strict and rigid application which would result in technicalities that tend to frustrate rather than promote substantial justice must always be avoided.”

FAQs

What was the key issue in this case?	The key issue was whether Seven Brothers Shipping Corporation could re-litigate matters already decided in a final and executory judgment. This case centered on the principle of finality of judgments and its enforcement.
What is the significance of a judgment being “final and executory”?	When a judgment is final and executory, it means that the decision can no longer be appealed or modified, except for clerical errors. It becomes the law of the case and must be enforced, ensuring the winning party receives the fruits of their victory.
What is the Limited Liability Rule in maritime law, and why was it not applied here?	The Limited Liability Rule generally limits a shipowner’s liability to the value of the vessel after an accident. However, this rule does not apply when the loss is due to the shipowner’s negligence, as the Court of Appeals found in this case.
What is a subrogee, and how does it relate to this case?	A subrogee is a party that steps into the legal position of another, typically an insured party, to pursue a claim against a third party responsible for the loss. In this case, Oriental Assurance acted as a subrogee after paying the insurance claim to Alcantara & Sons.
What did the Court of Appeals decide, and why was it significant?	The Court of Appeals reversed the RTC’s initial decision and found Seven Brothers liable for the loss of cargo due to the unseaworthiness of their vessel. This decision was significant because it established Seven Brothers’ negligence, precluding the application of the Limited Liability Rule.
Why did the Supreme Court uphold the Court of Appeals’ decision?	The Supreme Court upheld the Court of Appeals’ decision primarily because the decision had become final and executory. The Court emphasized that final judgments are immutable and cannot be altered or re-litigated, except for specific, limited reasons.
What was Seven Brothers’ main argument for quashing the writ of execution?	Seven Brothers argued that the levy on their vessels was invalid because one vessel was owned by another company and the sheriff did not properly demand payment before the levy. They also attempted to invoke the Limited Liability Rule.
How did the Court address the issue of the sheriff’s levy on the vessels?	The Court found that the sheriff’s levy was proper, noting that Seven Brothers did not disprove their inability to pay the judgment in cash. The Court also emphasized that the sheriff is not required to give the judgment debtor time to raise cash, especially when there is a risk of assets being lost.
What is the importance of procedural rules in legal proceedings?	Procedural rules are important for ensuring the effective enforcement of substantive rights through the orderly and speedy administration of justice. However, courts can interpret these rules liberally to promote substantial justice and prevent technicalities from frustrating the process.

In conclusion, the Supreme Court’s decision in this case reaffirms the fundamental legal principle of the finality of judgments. It underscores that once a court decision becomes final and executory, it must be enforced, preventing parties from endlessly re-litigating the same issues. This principle is crucial for maintaining the integrity and efficiency of the judicial system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Seven Brothers Shipping Corporation vs. Oriental Assurance Corporation, G.R. No. 140613, October 15, 2002

October 15, 2002