Cebu Salvage Corporation v. Philippine Home Assurance Corporation

Summary

This case establishes that a common carrier remains liable for cargo loss even when using a vessel it does not own. Cebu Salvage Corporation contracted to transport silica quartz but argued it was not liable when the chartered vessel M/T Espiritu Santo sank because it did not own the ship. The Supreme Court rejected this defense, ruling that a carrier's duties and liability are not negated by non-ownership of the transport vessel. The Court emphasized that allowing such a defense would undermine carrier obligations of extraordinary diligence and create dangerous precedent enabling carriers to escape liability through ownership technicalities. The decision reinforces that contractual relationships and representations as a carrier, not vessel ownership, determine liability in maritime transport cases.