Annie Tan v. Great Harvest Enterprises

Summary

This Supreme Court case involves the liability of common carrier Annie Tan for 430 bags of soya beans worth P230,000.00 that were stolen while in her custody. Great Harvest hired Tan to transport the goods, but when the consignee rejected delivery, her driver was instructed to bring them to Great Harvest's warehouse but absconded with the cargo instead. The Supreme Court affirmed lower court decisions holding Tan liable, emphasizing that common carriers must exercise extraordinary diligence over goods entrusted to them. The Court rejected Tan's arguments that the loss was a fortuitous event, finding instead that she failed to meet the required standard of care by not providing security, insurance, or properly vetting her driver. The decision reinforces the strict liability regime for common carriers under Philippine law, grounded in public policy considerations of allocative efficiency and the inherently inequitable dynamics between carriers and shippers.