Far Eastern Shipping Company v. Court of Appeals

Summary

This consolidated maritime tort case arose from the 1980 collision between M/V PAVLODAR and Manila International Port's Berth 4 during compulsory pilotage operations, causing over P1 million in pier damage. The Supreme Court En Banc affirmed the solidary liability of Far Eastern Shipping Company (vessel owner), pilot Senen Gavino, and Manila Pilots Association for concurrent negligence. The Court applied the maritime presumption of fault against moving vessels striking stationary objects and found that pilot Gavino failed to exercise the extraordinary care required in compulsory pilotage, while master Kavankov negligently failed to maintain vigilant oversight and intervene when danger became apparent. The decision clarified that pilots' association liability stems from administrative regulations rather than employer-employee relationships, establishing important precedent for maritime tort liability in Philippine admiralty law. The Court also addressed significant procedural issues regarding forum shopping certifications and professional responsibility of counsel.