Manuel Novo & Co. v. J. E. Ainsworth

Summary

Manuel Novo & Co. leased a barge and dredging scoop to J.E. Ainsworth under a contract making the lessee liable for loss or damage. When the barge sank during towage by lessor's launch after five days, both parties claimed damages. The Supreme Court held that the sinking was accidental, not caused by either party's negligence, applying Article 1902 of the Civil Code. The Court rejected both the lessor's claim for vessel value and damages and the lessee's claim for lost cargo, but awarded the lessor rental payments for the five-day use period. This case establishes that contractual liability for loss requires proof of fault or negligence, and accidental losses without proven negligence do not create liability under quasi-delict provisions.