- Petitioner
- San Miguel Corporation
- Respondent
- Heirs of Sabiniano Inguito
- Citation
- G.R. No. 141716
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Ynares-Santiago, J.
- Decided
- July 4, 2002
Summary
This consolidated case arose from the sinking of M/V Doña Roberta during Typhoon Ruping on November 13, 1990, killing 20 crew members. SMC had chartered the vessel from Julius Ouano under a Time Charter Party Agreement. Despite SMC's radio operator repeatedly advising the captain to take shelter, Captain Sabiniano Inguito (Ouano's employee) refused and continued the voyage, resulting in the vessel's sinking. The Supreme Court held that the charter was a contract of affreightment where Ouano retained control over the vessel and crew. SMC was absolved of liability as it exercised due diligence by warning the captain multiple times. Ouano was held vicariously liable under Civil Code Articles 2176 and 2180 for his employee's negligence, having failed to prove due diligence in selection and supervision. The Court ordered Ouano to compensate the crew members' heirs and indemnify SMC for the lost cargo, establishing important precedent on charterer liability and vicarious responsibility in maritime accidents.