Philippine Charter Insurance Corporation v. Neptune Orient Lines/Overseas Agency Services

Summary

This case involves a maritime cargo liability dispute where containers fell overboard during transport from Hong Kong to Manila due to heavy weather. Philippine Charter Insurance Corporation, after paying its insured's claim, sought full recovery from the carrier Neptune Orient Lines through subrogation. The Supreme Court affirmed the Court of Appeals' decision limiting the carrier's liability to US$500 per package under the bill of lading's limited liability clause. The Court rejected PCIC's argument that the carrier committed quasi deviation by intentionally jettisoning cargo, finding the facts established that containers fell overboard due to fortuitous events. The decision reinforced the validity of contractual liability limitations in maritime transport under both the Civil Code and COGSA, provided the shipper does not declare higher values and pay additional charges.