Aboitiz Shipping Corporation v. Hon. Court of Appeals

Summary

This case involves the death of passenger Anacleto Viana who was struck by a crane while retrieving cargo from Aboitiz Shipping Corporation's vessel M/V Antonia. The Supreme Court affirmed that the carrier-passenger relationship continued even one hour after disembarkation, as the passenger had the right to claim his baggage within a reasonable time. The Court applied the doctrine of extraordinary diligence required of common carriers, ruling that Aboitiz was presumed negligent and failed to rebut this presumption by showing adequate safety measures. Despite the victim's contributory negligence, the Court held that Aboitiz's failure to exercise extraordinary diligence was the proximate cause of death. The stevedoring contractor Pioneer was absolved of liability as its negligence was not established. The decision reinforces the strict liability standard for common carriers in protecting passenger safety and clarifies that the carrier-passenger relationship extends beyond mere transportation to include reasonable time for baggage retrieval.