Dsr-Senator Lines v. Federal Phoenix Assurance Co.

Summary

This case involves maritime cargo liability when artificial trees shipped from Manila to Saudi Arabia worth $34,579.60 were lost after the feeder vessel M/V Kapitan Sakharov caught fire and sank during transshipment. Federal Phoenix Assurance, having paid the P941,429.61 insurance claim, sought recovery from DSR-Senator Lines and ship agent C.F. Sharp through subrogation. The Supreme Court affirmed lower courts' decisions holding the carriers liable, ruling that fire is not among the exceptions under Civil Code Article 1734 that exempt common carriers from liability. The carriers were presumed negligent and failed to prove they exercised extraordinary diligence required by law. The decision reinforces the principle that common carriers bear strict liability for cargo loss unless they can prove extraordinary diligence and that specific exceptions in Article 1734 apply.