Aleson Shipping Lines v. Cgu International Ins. Plc.

Summary

This maritime collision case involved two vessels in Apo channel where M/V Aleson Carrier 5 struck M/V Romeo, causing the latter to sink with valuable cement cargo. The Supreme Court clarified the distinction between contract-based and tort-based causes of action in maritime cases. While contract-based claims against common carriers are governed by Civil Code provisions requiring extraordinary diligence, tort-based claims arising from maritime collisions are governed by Code of Commerce provisions requiring ordinary diligence. The Court found Aleson Shipping liable under maritime tort law, as its captain failed to exercise ordinary diligence by not verifying radio clearance, not using sound signals, and not maneuvering to avoid collision despite having opportunity and space to do so. The decision established important precedent on the applicable legal framework for maritime collision liability depending on the nature of the cause of action.