G. Urrutia & Co. v. Baco River Plantation Co.

Summary

This landmark maritime collision case established important precedents for vessel liability under International Rules for Prevention of Collisions at Sea. The Supreme Court applied the three-zone theory of collision avoidance, holding that steamships must maintain safe distance from sailing vessels and cannot place them in situations requiring split-second decisions. The Court ruled that a sailing vessel's duty to maintain course is absolute except in extremis situations created by the other vessel's negligence. The decision also established that insurance proceeds from a negligent vessel can be used to satisfy damage judgments against the vessel owner, applying Civil Code article 1186. This case demonstrates the strict liability standards applied to steamships in maritime collisions and the protective presumption favoring sailing vessels in collision cases.