Jaime Sabeniano, Jr. v. The Court of Appeals

Summary

This case involves the liability of a customs broker for damaged cargo during transport. American Home Assurance Company insured a shipment of steel tool bits from Scotland to Manila. Upon delivery, shortages and breakages worth P104,973.61 were discovered. The insurer paid the claim and sought recovery from various parties including customs broker Jaime Sabeniano Jr. The Supreme Court affirmed that Sabeniano, as a customs broker who transported goods from port to consignee, was a common carrier under Civil Code Article 1732. As such, he was bound to exercise extraordinary diligence under Articles 1733-1735. Since he failed to prove such diligence despite knowing the goods were damaged, the presumption of negligence applied, making him jointly and severally liable for P74,972.61. The decision establishes that customs brokers who transport goods are common carriers subject to extraordinary diligence standards.