Sulpicio Lines v. Domingo E. Curso

Summary

This Supreme Court case resolved whether surviving siblings can recover moral damages for breach of contract of carriage resulting in passenger death. Dr. Cenon Curso died when MV Doña Marilyn sank during Typhoon Unsang in 1988. His brothers and sisters sued Sulpicio Lines for damages. The RTC dismissed for force majeure, but the CA reversed, awarding moral damages to siblings. The Supreme Court granted Sulpicio Lines' petition, holding that Article 2206(3) of the Civil Code limits moral damages for passenger death to spouses, descendants, and ascendants only, excluding collateral relatives like siblings. The decision clarified the statutory limitation on who may recover moral damages in maritime carrier liability cases, applying the inclusio unius est exclusio alterius principle to exclude siblings from moral damage awards despite their inheritance rights.