Negros Navigation VS Court of Appeals (GR NO.

110398) 7 November 1997 Petition: Review for certiorari of the decision of the Court of Appeals affirming with modification the Regional Trial Courts award of damages to private respondents for the death of relatives which resulted from the sinking of petitioners passenger sea vessel. Petitioner: Negros Navigation Co., Inc. Respondents: Court of Appeals, Ramon Miranda, Sps. Ricardo and Virginia de la Victoria. Ponente: J. Mendoza Pertinent Principle/Concept of StatCon: Stare Decisis FACTS: Sometime in April 1980, Ramon Miranda, one of the private respondents in this case purchased four special tickets (Numbers 74411, 74412, 74413 and 74414) from the petitioner for his wife, children and niece who were then bound to leave for Bacolod City to attend a family reunion. On 22 April 1980, private respondents aforementioned relatives boarded M/V Don Juan of Negros Navigation Co., Inc., that was leaving Manila at 1:00 PM. As expected, said vessel sailed on time. However, on the evening of 22 April, petitioners vessel collided with the M/T Tacloban City- an oil tanker owned by the Philippine National Oil Corporation (PNOC) and the PNOC Shipping and Transport Corporation (PNOC/STC). Obviously, several passengers perished in the sea tragedy. Some bodies were found, and some, including the relatives of private respondents were never found. Knowing the ill-fate of the M/V Don Juan, private respondents, namely Garcia and Sps de la Victoria filed a complaint against the Negros Navigation, the PNOC, and the PNOC/STC. Private respondents sought for damages for the death of their relatives namely Ardita de la Miranda, Rosario V. Miranda, Ramon Miranda Jr., and Elfreda de la Victoria. The RTC rendered a decision in favor of the private respondents, and asked petitioners, including PNOC and PNOC/STC to pay the moral damages sought by Garcia and Sps. de la Victoria. And upon review by the Court Appeals, the appellate court affirmed the RTCs decision with several modification. ISSUES: Several issues were raised in this case. However, for the sake of having a discourse on the abovementioned principle/concept of Statutory Construction, we shall focus on the issue of whether or not the ruling in the Mecenas VS CA, finding the crew members of petitioners to be grossly negligent in the performance of their duty, is binding in this case. HELD: Yes. The courts adherence to the Mecenas Case1 is dictated by the principle of stare decisis et non quieta movere (Follow past precedents and do not disturb what has been settled). The petitioners assail the lower courts reliance on the Mecenas Case, arguing that although the same case arose out of the same incident as that involved in the Mecenas, THE PARTIES ARE DIFFERENT AND TRIALS WERE CONDUCTED SEPARATELY. Furthermore they contend that the decision in this case must be based on the allegations, the defenses pleaded and evidence adduced stated on the records of the case.

The Mecenas Case is another case arising from the incident that occurred on 22 April 1980.

 The Supreme Court ruled otherwise. The Supreme Court stated that although the merits of the individual claims against the petitioner are different in both cases, there remains a similarity which is material in the decision of the court vis--vis the case at hand, i.e. the cause of the sinking of its ship on 22 April 1980 and the liabilities (of petitioner) for such accident. DOCTRINE STARE DECISIS o Stare decisis et non quieta movere (Follow past precedents and do not disturbed what has been settled). o Under the principle of Stare Decisis, it is required that past decisions of the court be followed in the adjudication of cases. o A ruling of the supreme court as to the construction of a law should be followed in subsequent cases INVOLVING SIMILAR QUESTIONS. o The principle presupposes that the facts of the precedent and the case to which it is applied are substantially the same. If facts are dissimilar, then the aforementioned principle does not apply. o Purpose of this principle is to have stability in the law.

The doctrine of stare decisis applies in this case. It is a rule that a ruling of the court as to the construction of a law should be followed in subsequent cases INVOLVING SIMILAR QUESTIONS. Although the personal circumstances and claims of Mecenas, and Miranda and de la Victoria are different as contended by the petitioner, the two cases raised similar question/issue, i.e. on the damages for which the petitioner was liable due to the sinking of its ship.