Mitsui O.S.K. Lines Ltd… · G.R. 119571

Petitioner: Mitsui O.S.K. Lines Ltd.
Respondent: Court of Appeals
Citation: G.R. No. 119571
Court: Supreme Court
Division: Second Division
Ponente: Mendoza, J.
Decided: March 11, 1998

Summary

This Supreme Court case resolved whether damages from delayed delivery of goods fall under the Carriage of Goods by Sea Act's one-year prescriptive period or the Civil Code's ten-year period. Mitsui O.S.K. Lines failed to deliver Lavine Loungewear's goods from Manila to France within the promised 28 days due to transshipment delays, causing the goods to arrive during off-season and reducing their market value. The Supreme Court distinguished between physical loss/damage to goods (covered by COGSA's shorter prescription) and contractual damages from delayed delivery affecting market value (governed by Civil Code's longer prescription). The Court affirmed that the action was not barred by COGSA's one-year limitation, establishing important precedent for maritime law regarding the scope of 'loss or damage' under COGSA versus general contract breach remedies.

Statutes applied

Civil Code, Art. 1144

Related cases

Other Philippine cases on the same provisions and issues.

Anq Construction Corporation v. Ultra Petronne Interior Supply Corporation G.R. No. 251944
Vicelet Lalicon v. National Housing Authority G.R. No. 185440
Unlad Resources Development Corporation v. Renato P. Dragon G.R. No. 149338
Dan Fue Leung v. Hon. Intermediate Appellate Court G.R. No. 70926
Filcon Ready Mixed v. Ucpb General Insurance Company G.R. No. 229877
Maxima P. Saclolo v. Romeo Marquito G.R. No. 229243
Thelma C. Muller v. Philippine National Bank G.R. No. 215922
Marcelino S. Andrino v. Top Services G.R. No. 237028

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By the Intellegal Editorial Board · March 11, 1998

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