Lorenzo Shipping Corporation v. National Power Corporation

Summary

This consolidated case involves a maritime collision where MV Lorcon Luzon rammed Power Barge 104 at Makar Wharf on March 20, 1993, while under compulsory pilotage. The Supreme Court established that compulsory pilotage does not automatically absolve vessel owners of liability when the master fails to exercise proper vigilance. Captain Villarias was found negligent for waiting six minutes without taking action when the engine failed to respond to the pilot's orders to reverse. The Court applied the presumption of fault against moving vessels striking stationary objects and rejected the assumption of risk defense. While National Power Corporation could not prove exact damages due to inadmissible evidence, the Court awarded P300,000.00 in temperate damages, recognizing that some pecuniary loss occurred even when the precise amount cannot be established with certainty. The decision clarifies the intertwined responsibilities of pilots and masters in maritime operations and the standards for proving damages in civil cases.