Nedlloyd Lijnen B.V. Rotterdam v. Glow Laks Enterprises

Summary

This case involves the liability of foreign shipping companies Nedlloyd and East Asiatic for misdelivery of garments worth US$53,640.00 shipped from Manila to Panama. The goods were released to unauthorized persons who presented forged bills of lading to Panama's port authority. The Supreme Court ruled that Panamanian law was not properly proven under Philippine rules of evidence, requiring application of domestic law. Under the Civil Code, common carriers bear extraordinary responsibility until actual delivery to consignees. Since the goods were never delivered to the rightful consignee but fell into unauthorized hands, the carriers failed to overcome the presumption of negligence. The Court held that discharge to port authorities does not terminate carrier liability, which continues until proper delivery to consignees or their authorized agents.