- Petitioner
- Designer Baskets
- Respondent
- Air Sea Transport
- Citation
- G.R. No. 184513
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Jardeleza, J.
- Decided
- March 9, 2016
Summary
This commercial law case involved Designer Baskets Inc. (DBI) seeking payment from buyer Ambiente and carriers ASTI/ACCLI for goods delivered without bill of lading surrender. DBI, an exporter, shipped wooden items worth US$12,590.87 to US-based Ambiente through carriers ASTI and its Philippine agent ACCLI. When Ambiente failed to pay, DBI retained the original bills of lading. However, ASTI released the goods to Ambiente pursuant to an Indemnity Agreement without bill of lading surrender and without DBI's knowledge. The Supreme Court ruled that carriers are not liable for releasing goods without bill of lading surrender when supported by proper indemnity, as Article 353 of the Code of Commerce permits such release when consignee cannot return the bill of lading 'for any other cause.' The Court emphasized that contracts of carriage are distinct from contracts of sale, and carriers' obligations are limited to safe delivery, not ensuring buyer payment. Only Ambiente remained liable for the unpaid purchase price.