Oceaneering Contractors (Phils.) v. Nestor N. Barretto

Summary

This case establishes strict requirements for actual damages awards in breach of contract cases involving maritime charters. Oceaneering chartered Barretto's barge for construction material transport, but the vessel sank near Batangas. While the Court of Appeals found Barretto liable as a common carrier who failed to overcome the presumption of negligence from the sinking, the Supreme Court emphasized that actual damages must be proven with reasonable certainty using the best available evidence. The Court granted only damages supported by documentary evidence (P2,226,620.00 for proven cargo loss) and rejected unsupported claims, demonstrating the fundamental principle that self-serving statements cannot substitute for corroborative evidence in damages awards. The decision clarifies that even when liability is established, damages recovery requires strict adherence to evidentiary standards under Civil Code Article 2199.