Eastern Shipping Lines v. Court of Appeals

Summary

This case involved the solidary liability of a common carrier (Eastern Shipping Lines), arrastre operator (Metro Port Services), and customs broker (Allied Brokerage Corporation) for damages to a shipment of riboflavin that sustained losses while in their successive custody. Mercantile Insurance Company, as subrogee, sought recovery of P19,032.95 paid to the consignee. The Supreme Court affirmed the solidary liability but modified the interest computation, establishing comprehensive guidelines for legal interest in damage awards. The Court distinguished between obligations involving loans/forbearance of money (12% interest) and indemnity for damages (6% interest), with different rules for when interest begins to run. The decision clarified that for unliquidated damages, 6% interest runs from the court decision date, not from complaint filing, with 12% interest applying from finality of judgment until payment. This case significantly contributed to Philippine jurisprudence on carrier liability and interest computation in damage awards.