Sulpicio Lines v. Napoleon Sesante

Summary

This case involves the sinking of M/V Princess of the Orient on September 18, 1998, resulting in 150 deaths out of 388 passengers. Survivor Napoleon Sesante sued Sulpicio Lines for breach of contract of carriage. The Supreme Court affirmed the common carrier's liability under Articles 1756 and 1759 of the Civil Code, rejecting the force majeure defense. The Board of Marine Inquiry found that the captain's erroneous maneuvering during stormy weather was the immediate and proximate cause of the sinking, constituting negligence that rendered the carrier liable. The Court awarded P1,000,000 moral damages recognizing the trauma of survival, P120,000 temperate damages for lost belongings, and P1,000,000 exemplary damages for the wanton and reckless conduct. The decision emphasizes that common carriers must observe extraordinary diligence in ensuring passenger safety and cannot escape liability when human agency contributes to maritime disasters, even during adverse weather conditions.