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I.

Letter of Credit

A letter of credit is a financial device developed by merchants as a convenient and relatively safe mode of dealing
with the sales of goods to satisfy the seemingly irreconcilable interests of a seller, who refuses to party with his goods before he
is paid, and a buyer who wants to have control of the goods before paying.

A letter of credit is one whereby one person request some other person to advance money or give credit to a third
person, and promises that he will repay the same to the person making the advancement, or accept the bills drawn upon
himself for the like amount.

Rights and Obligations of Parties

A notifying bank assumes no liability except to notify and/or transmit to the beneficiary the existence of the letter of
credit.

The notifying bank may suggest to the seller its willingness to negotiate, but this fact alone does not imply that the
notifying bank promises to accept the draft drawn under the documentary credit.

A negotiating bank buys or discounts a draft under the letter of credit. Its liability is dependent upon the stage of the
negotiation. If before the negotiation, it has no liability with respect to the seller, but after negotiation, a contractual
relationship will prevail between the negotiating bank and the seller. A confirming bank assumes a direct obligation to the
seller, and its liability is a primary one as if the bank itself had issued the letter of credit.

A notifying bank is not privy to the contract of sale between the buyer and seller, its relationship is only with that of
the issuing bank and not with the beneficiary to whom he assumes no liability. Furthermore, confirmation of a letter of credit
must be expressed.

The notifying bank does not have any contractual relationship with the buyer, it has also nothing to do with the
contract between the issuing bank and the buyer regarding the issuance of the letter of credit.

Problem:

Bravo Bank received form Cisco Bank by registered mail an irrevocable letter of credit issued by Delta Bank for the
account of Y Company in the amount of US $10M to cover the sale of canned fruit juices. The beneficiary of the letter of credit
was X Corp which later on partially availed itself of the letter of credit by submitting to Bravo Bank all documents relative to the
shipment of the cans of fruits juices. Bravo Bank paid X Corp for its partial availment. Later, however, it refused further
availment because of suspicious of fraud being practiced upon it and, instead sued X Corp to recover what it had been paid later.
How would you rule if you were the Judge?

Answer:

If I were the judge, I would rule that Bravo Bank may recover from X Corp. Bravo Bank was only an advising or
notifying bank, and did not assume the responsibility of a confirming bank. When Bravo Bank later paid X Corp upon the
latter's submission of the required documents, a discounting arrangement occurred. Bravo Bank, this time, acted as a
negotiating bank, thereby saving X Corp from the hardship of presenting the documents directly to Delta Bank to recover
payment. As a negotiating bank, Bravo Bank has a right of recourse against Delta Bank and until reimbursement is obtained,
X Corp, as the drawer of the draft, continues to assume a contingent liability thereon.

Problem:
In letter of credit in banking transactions, distinguish the liability of a confirming bank from a notifying bank?

Answer:

An advising or notifying bank does not incur any obligation more than just notifying the beneficiary of the letter of
credit issued in its favor. It is not liable for a breach of the letter of credit. An advising bank is bound only to check the
"apparent authenticity" of the letter of credit. A confirming bank assumes a direct obligation to the seller, and its liability is
primary one as if the bank itself issued the letter of credit. A confirming bank is to honor all drafts drawn in conformity with
the letter of credit.

Basic Principles

1. Doctrine of Strict Compliance

The letter of credit evolved as a mercantile specialty, and the only way to understand all its facets is to recognize that
it is an entity unto itself. The relationship between the beneficiary and the issuer of the letter of credit is not strictly contractual,
because both privity and a meeting of the minds are lacking, yet strict compliance with each term is an enforceable right. Thus,
upon receipt by the issuing bank of the documents of title which conform with what the letter of credit requires., it is duty
bound to pay the seller. Nor is it a third party beneficiary contract, because the issuer must honor drafts against a letter
regardless of problems subsequently arising in the underlying contract. Since the bank's customer cannot draw on the letter, it
does not function as an assignment by the customer to the beneficiary. Nor is it a contract of suretyship or guarantee, because
it entails a primary liability following a default.

The rule of strict compliance in a letter of credit transaction means that the documents tendered by the seller or
beneficiary must strictly conform to the terms of the letter of credit. They must include all documents required by the letter of
credit. Thus, a correspondent bank which departs from what has been stipulated, under the letter of credit, as when it accepts
a faulty tender, acts on its own risk and may not thereafter be able to recover from the buyer or the issuing bank, as the case
may be, the money thus paid to the beneficiary.

Problem:

BV agreed to sell to AC, a ship and merchandise broker, 2,500 cubic meters of logs at $27 per cubic meter. After
inspecting the logs, CD issued a purchase order.

On the arrangements made upon instruction of the consignee, H&T Corp of Los Angeles, California, the SP Bank of Los
Angeles issued a irrevocable letter of credit available at sight in favor of BV for the total purchase price of the logs. The letter of
credit was mailed to Feati Bank with the instruction to forward it to the beneficiary. The letter of credit provided that the draft
to be drawn is on SP Bank and that it be accompanied by, among other things, a certification from AC stating that the logs have
been approved prior to shipment in accordance with the terms and conditions of the purchase order.

Before loading on the vessel chartered by AC, the logs were inspected by customs inspectors and representatives of
the Bureau of Forestry, who certified to the good condition and exportability of the logs. After the loading was completed, the
Chief Mate of the vessel issued a mate receipt of the cargo which stated that the logs are in good condition. However, AC
refused to issue the required certification in the letter of credit. Because of the absence of certification, Feati Bank refused to
advance payment on the letter of credit.

(a) May Feati Bank be held liable under the letter of credit? Explain
(b) Under the facts stated above, the seller, BV, argued that Feati Bank, by accepting the obligation to notify him that
the irrevocable letter of credit has been transmitted to it on his behalf, has confirmed the letter of credit. Consequently, Feati
Bank is liable under the letter of credit. Is the argument tenable? Explain.

Answer:

(a) No, Feati Bank may not be held liable under the letter of credit. The letter of credit provides as a condition a
certification from AC. Without such certification, there is no obligation on the part of Feati Bank to advance payment of the
letter of credit.

Furthermore, commercial transactions involving letters of credit are governed by the rule of strict compliance. Well
settled is the rule that in commercial transactions involving letters of credit that the documents tendered must strictly
conform to the terms of the letter of credit. The tender of documents by the beneficiary (seller) must include all documents
required by the seller. A correspondent bank which departs from what has been stipulated under the letter of credit, as when
it accepts a faulty tender, acts on its own risks and it may be thereafter able to recover from the buyer or the issuing bank, as
the case may be, the money thus paid to the beneficiary.

(b) No, the argument of BV is not tenable. Feati Bank may have confirmed the letter of credit when it notified BV
that an irrevocable letter of credit has been transmitted to it on his behalf but the conditions in the letter of credit must first
be complied with, namely, that the draft must be accompanied by a certification from AC. A notifying bank is not privy to the
contract of sale between the buyer and seller, its relationship is only with that of the issuing bank and not with the
beneficiary to whom he assumes no liability. Furthermore, confirmation of a letter of credit must be expressed.(Feati Bank vs
CA)

Problem:

Carlo imported 1,000 rubber boots from China under his purchase contract with the Chinese manufacturer, Chen
Wha Ltd., the boots must have a half-inch sole. To pay for such importation, Carlo opened a letter of credit with XYZ Bank in
favor of Chen WHa. When the boots arrived, Carlo found that the soles of the boots were only a quarter of an inch thick. He
cried "fraud" and immediately advised XYZ Bank not to pay on the letter of credit. However, the bank disregarded Carlo's advice
and paid Chen Wha upon the latter's submission of the documents required under the letter of credit. Was the action of the
bank proper?

Answer:

Yes, the action of the bank was proper. Under the "independence principle" in a letter of credit transaction, a bank,
in determining compliance with the terms of a letter of credit is required to examine only the shipping documents presented
by the seller and is precluded from determining whether the main contract is actually accomplished or not. This arrangement
assures the seller of prompt payment, independent of any breach of the main sales contract.

Problem:

RB had a savings account and a current account with RCBC. These two accounts had an "automatic transfer" condition
wherein checks issued by the depositor may be funded by any of the two accounts. On 1992, RB purportedly signed a
Comprehensive Surety Agreement with RCBC in favor of nine corporations. Under the Surety Agreement, the funds in RB's
accounts with RCBC would be used as security to guarantee any existing and future loan obligations, advances, credits/increases
and other obligations, including any and all expenses that these corporations may incur with RCBC.

RB contests that veracity and due authenticity of the Surety Agreement on the ground that his signature was not
genuine and that the agreement was not notarized.
RCBC issued four letter of credits to four of the nine corporations .

Answer:

What must be underscored in RCBC's immediate action of applying petitioner RB's account to the Lotec Marketing is
that nature of the loan instrument used in this case -- letter of credit. In a letter of credit, the engagement of the issuing bank
(RCBC) is to pay the seller or beneficiary of the credit once the draft and the required documents are presented to it. This
"independence principle" in letters of credit assures the seller or the beneficiary of prompt payment independent of any
breach of the main contract and precludes the issuing bank from determining whether the main contract is actually
accomplished or not.

In this case, RCBC, as the issuing bank for Lotec Marketing's letter of credit had to make prompt payment to Korea
Exchange Bank (advising bank) when the obligation became due and demandable. Precisely, because of the independence
principle in letters of credit and the need for prompt payment, RCBC required a Surety Agreement from RB before issuing the
letters of credit in favor of the four corporations, including Lotec Marketing. (Bangayan vs. RCBC)

Letters of credit are not negotiable instruments, but drafts issued in connection with letters of credit are negotiable instruments.
The presumption that the drafts drawn in connection with the letters of credit have sufficient consideration applies.

While the presumption found under the NIL may not necessarily be applicable to trust receipts and letters of credit, the
presumption that the drafts drawn in connection with the letters of credit have sufficient consideration. The letters of credit
show that the pertinent materials/merchandise have been received by MICO. The drafts signed by the beneficiary/suppliers in
connection with the corresponding letters of credit proved that the said suppliers were paid by PBCom for the account of Mico.
(Lee vs CA)

The concept of guarantee vis--vis the concept of an irrevocable letter of credit are inconsistent with each other. The guarantee
theory destroys the independence of the bank's responsibility from the contract upon which it was opened and the nature of
both contracts is mutually in conflict with each other. In contracts of guarantee, the guarantor's obligation is merely collateral
and it arises only upon the default of the person primary liable. While in a irrevocable letter of credit, the bank undertakes a
primary obligation. (MWSS vs. DAWAY)

The participating bank's obligation are solidary with respondent Maynilad in that it is a primary, direct, definite and an absolute
undertaking to pay and is not conditioned on the prior exhaustion of the debtors assets. Being solidary, the claims against them
can be pursued separately from and independently of the rehabilitation case, as held in Traders Bank vs. CA, where we said that
property of the surety cannot be taken into custody by the rehabilitation receiver and said surety can be sued separately to
enforce his liability as surety for the debts or obligations of the debtor. (MWSS vs. DAWAY)

Except when a letter of credit specifically stipulates otherwise, the obligation of the banks issuing letters of credit are solidary
with that of the person or entity requesting for its issuance, the same being a direct, primary, absolute and definite undertaking
to pay the beneficiary upon the presentation of the set of documents required therein. (MWSS vs. DAWAY)

Doctrine of Independence

The relationship of the buyer and the bank is separate and distinct from the relationship of the buyer and seller in the
main contract; the bank is not required to investigate if the contract underlying the letter of credit has been fulfilled or not
because in transactions involving letters of credit, banks deal only with documents and not goods.

What is the two fold nature of the Independence Principle?


1. Independence in toto where the credit is independent from the justification aspect and is a separate obligation from the
underlying agreement. The principle is illustrated by standy letter of credit;

2. Independence only as to the justification aspect which is identical with the same obligations under the underlying
agreement. This principle is illustrated by a commercial letter of credit or repayment standby.

Problem:

The Supreme Court has held that fraud is an exception to the "independence principle" governing letters of credit.
Explain this principle and give an example of how fraud can be an exception.

Answer:

The "independence principle" in a letter of credit assures the seller or the beneficiary of prompt payment
independent of any breach of the main contract and precludes the issuing bank from determining whether the main contract
is actually accomplished or not. Under this principle, banks assume no liability or responsibility for the form, sufficiency,
accuracy, genuineness, falsification or legal effect of any documents, or for the general and/or particular conditions stated in
the documents or superimposed thereon, nor do they assume any liability or responsibility for the description, quantity,
weight, quality, condition, packing, delivery, value or existence of the goods represented by any documents, or for the good
faith or acts and/or omissions, solvency, performance or standing of the consignor, the carriers, or the insurers of the goods,
or any other person whomsoever.

Fraud exception exists when the beneficiary, for the purpose of drawing on the credit, fraudulently presents to the
confirming bank documents that contain, expressly or by implication, material representations of fact that to his knowledge
are untrue.

Fraud Exception Principle

This principle provides that the untruthfulness of a certificate accompanying a demand for payment under a standby
letter of credit may qualify as fraud sufficient to support an injunction against payment.

This principle refers to fraud in relation with the independent purpose or character of the letter of credit and not only
fraud in the performance of the obligation or contract supporting the letter of credit.

Injunction against payment is the remedy provided the following requisites are presest:

a) Clear proof of fraud

b) Fraud constitutes fraudulent abuse of the independent purpose of the letter of credit and not only fraud under the
main agreement

c) Irreparable injury might follow if injunction is not granted or the recovery of damages would be seriously damaged.

II. Warehouse Receipts Law


A. Nature and functions of a warehouse receipt

Definition

A warehouse receipt is a written acknowledgment by the warehouseman that he has received and holds certain goods
therein described in his warehouse for the person to whom the document is issued.

Purpose.

The purpose of the law is to prescribe the rights and duties of a warehouseman and to regulate the relationship
between warehouseman and (i) the depositor of goods, or (ii) the holder of a warehouse receipt for the goods, or (iii) the
person lawfully entitled to the possession of the goods or (iv) other persons.

Who may issue warehouse receipts

A warehouse receipts may be issued by a warehouseman, whether public or private, bonded or not, and a person
authorized by the warehouseman.

Form and content of the warehouse receipts

It need not be in particular form but must embody within its written or printed terms.

1. Location of the WH

2. Consecutive number of the receipt

3. Date of the issue

4. A statement whether the goods received will be Delivered to bearer, or to a specified person or to a specified person or his
order.

5. Signature of the WHM

6. If the receipt is issued for goods of which the WHM is the owner, either solely or jointly or in common with others, the fact of
such ownership; and

7. Description of goods

8. A statement of the amount of advances made and of liabilities incurred for which the WHM claims a lien.

9. Fees.

Effect of omission of any of the essential terms

1. Conversion of the contract to ordinary deposits.

2. Injured person can hold WHM liable for all damages caused by the omission.

3. Validity of the receipt is not affected.

4. Negotiability of receipts not affected.

Terms that cannot be included


A warehouseman may insert in a receipt issued by him, any other terms and conditions provided that such terms and
conditions shall not be:

1. Contrary to the Warehouse Receipts Law

2. Contrary to law, morals, good customs, public order or public policy

3. Terms reducing the required diligence of the WHM

4. Those exempting the WHM from liability for misdelivery or for not giving statutory notice in the case of sale of
goods

5. Those exempting the WHM from liability for negligence

To whom delivered

The goods should be delivered to the:

1. person lawfully entitled to the possession of the goods, or his agent

2. person entitled to Delivery under a non-negotiable instrument or with written authority; or

3. lawful order of a negotiable receipt. (person in possession of a negotiable instrument).

Kinds of Warehouse receipts

1. Negotiable warehouse receipt

It is a receipt in which it states that the goods received will be delivered to the bearer or to the order of any person
named in such receipt. It is negotiated by delivery or indorsement plus delivery.

Who may negotiate a negotiable WR?

1. the owner

2. any person to whom the possession or custody of the receipt has been entrusted by the owner, if, by the terms of
the receipt, the goods are deliverable to the order of the person to whom the possession or custody of receipt has been
entrusted or in such form that it may be negotiated by delivery.

What happens if the indorsement is necessary but the negotiable receipt was only delivered?

1. the transferee Acquires title against the transferor

2. there is not direct obligation of the WHM

3. the transferee can compel the transferor to complete the negotiation by indorsing the instrument. Negotiation
takes effect as of the time when the indorsement is actually made.
In case of the signature of an owner of a negotiable WR was forged and the forger who now holds the negotiable receipt was
able to withdraw the goods from the WHM. What are the rights of the owner of the negotiable receipt?

a. if under WHR, the goods are deliverable to the depositor or to his order, the owner of said negotiable receipt may
proceed against the WHM and/or the holder.

b. without the valid indorsement of the owner to the holder or in blank, the WHM is liable to the owner for
conversion in the misdelivery.

c. if the goods are deliverable to bearer, the owner may only proceed against the holder. The WHM is not liable for
conversion where the goods are delivered to a person in possession of a bearer negotiable instrument.

What is the rule when more than one negotiable receipt was issued for the same goods?

A WHM shall be liable for all damages caused by his failure to do so to anyone who purchased the subsequent receipt
for value supposing it to be an original, even though the purchase be after the delivery of the goods by the WHM to the holder
of the original receipt.

2. Non-negotiable warehouse receipt

It is a receipt in which it is stated that the goods received will be delivered to the depositor or to any other specified
person.

How is a non-negotiable WHR transferred?

A non-negotiable WR receipt may be transferred by its delivery to the transferee accompanied by a deed of
assignment, donation or other form of transfer.

What is the effect of indorsement of a non-negotiable WR?

Even if the receipt is indorsed, the transferee acquires no additional right.

Q: Coco was issued by a WHM a negotiable receipt for safekeeping by the latter of his goods. Can the judgment creditor
of Coco levy by execution the goods covered by the negotiable receipt?

A: The goods cannot, while in the possession of the WHM, be attached by garnishment or otherwise, or be levied upon
under an execution unless the receipt be first surrendered to the WHM, or its negotiation enjoined. The warehouseman cannot
be compelled to deliver the actual possession of the goods until the receipt is surrendered to it or impounded by the court.

Q: Assuming that prior to the levy, the receipt was sold to Yoyo on the basis of which he filed a claim with the sheriff.
Would Yoyo have better rights to the goods than the creditor?

A: Yes. Yoyo, as a holder for value of the receipt, has a better right to the goods than the creditor. It is Yoyo that can
surrender the receipt which is in its possession and can comply with the other requirements which will oblige the
warehouseman to deliver the goods, namely, to sign a receipt for the delivery of the goods, and to pay the warehouseman's
liens and fees and other charges.

Q: What is the proper recourse of the WHM if he is uncertain as to who is entitled to the goods?

A: Since there is conflicting claim of ownership or title, the warehouseman should file a complaint in interpleader
requiring the claimants to interplead. The matter involves a judicial question as to whose claim is valid.

Q: What is the rule where a warehouse receipt is transferred to secure payment of a loan by way of pledge or mortgage?

A: the pledge or mortgagee does not automatically become the owner of the goods but merely retains the right to keep,
and with the consent of the owner to sell them so as to satisfy the obligation from the proceeds for the simple reason that the
transaction is not a sale but only a mortgage or pledge. Likewise, if the property is lost without the fault or negligence of the
mortgagee or pledge, then said goods are to be regarded as lost on account of the real owner, mortgagor or pledgor.

Q: Does the non-payment by the original depositors of the purchase price render the further negotiation of the receipt
invalid?

A: No. The negotiation of the warehouse receipt by the buyer of goods purchased from and deposited to the
warehouseman is valid even if the warehouseman who issued the negotiable warehouse receipt was not paid by the buyer. The
validity of the negotiation cannot be impaired by the fact that the owner/warehouseman was deprived of the possession of the
same by fraud, mistake or conversion.

Q: When is refusal to deliver by the WHM justified?

A: 1. If the warehouseman's lien is not satisfied by the claimants.

2. Where the goods have already been sold to satisfy the warehouseman's lien or because of their perishable or
hazardous nature.

3. If the warehouse receipt is negotiated back to him.

4. When the holder does not satisfy the conditions prescribed in Sec 8:

a. Non-satisfaction of WHM's lien

b. Failure to surrender warehouse receipt

c. Refusal to sign the Acknowledgement receipt, acknowledging the receipt of the goods from the
warehouse

5. The failure was not due to any fault on the part of the WHM:

a. Upon request by or on behalf of the person lawfully entitled

b. If the goods are lost, due to a fortuitous event exclusively

c. If the WHM needs reasonable to ascertain the validity of the claim if someone other than the depositor
claims title to the goods

d. If he had information that the delivery about to be made was to one not lawfully entitled

e. If several persons claim the goods.

Q: What is the remedy if the WHR is lost or destroyed?


A: A court of competent jurisdiction may order the delivery of the goods only:

a. Upon satisfactory proof of the loss or destruction of the receipt; and

b. Upon the giving of a bond with sufficient sureties to be approved by the court.

Note: The delivery of the goods under an order of the court shall NOT relieve the WHM from liability to a person to whom the
negotiable receipt has been or shall be negotiated for value without notice of the proceedings or of the delivery of the goods.

Q: What are the remedies available to a WHM to enforce his WHM's lien?

A: 1. By refusing to deliver the goods until the lien is satisfied;

2. By causing the extra judicial sale of the property and applying the proceeds of the value to the lien;

3. By filing a civil action for collection of the unpaid charges by way of counterclaim in an action to recover the
property from him or such other remedies allowed by law for the enforcement of a lien against personal property or to a
creditor against his debtor, for the collection from the depositor of all the charges which the depositor has bound himself to pay.

Q: Does the lien over the goods preclude the WHM to avail all other remedies?

A: No. Whether a warehouseman has or has not a lien upon the goods, he is entitled to all remedies allowed by law to a
creditor against a debtor for the collection from the depositor of all charges and advances which the depositor has expressly or
impliedly contracted with the warehouseman to pay.

Problem:

S stored hardware materials in the bonded warehouse of W, a licensed warehousemen under the General Bonded
Warehouse law. W issued the corresponding warehouse receipt in the form he ordinarily uses for such purpose in the course of
his business. All the essential terms required under Sec 2 of Act 2137 are embodied in the form. In addition, the receipt issued
to S contains a stipulation that W would not be responsible for the loss of all or any portion of the hardware materials covered
by the receipt even is such loss is caused by the negligence of W or his representatives or employees. S endorsed and
negotiated the warehouse receipt to B, who demanded delivery of the goods. W could not deliver because the goods where
nowhere to be found in his warehouse. He claims he is not liable because of the free-from-liability clause stipulated in the
receipt. Do you agree with W's contention?

Answer:

No. I do not agree with the contention of W. While Sec. 3 of the warehouse receipts Act allows a warehouseman
insert in a receipt issued by him any other terms and conditions, such terms and conditions shall not be contrary to the
provisions of the Act and in any wise impair his obligation to exercise that degree of care in the safekeeping of goods
entrusted to him which a reasonably careful man would exercise in regard to similar goods of his own. The said free-from-
liability clause is, therefore, void.

The relationship therefore between the consignee and the arrastre operator must be examined. This relationship is
much akin to that existing between the consignee or owner of shipped goods and the common carrier, or that between
a depositor and a warehouseman [[22]]. In the performance of its obligations, an arrastre operator should observe the
same degree of diligence as that required of a common carrier and a warehouseman as enunciated under Article
1733 of the Civil Code and Section 3(b) of the Warehouse Receipts Law, respectively. Being the custodian of the goods
discharged from a vessel, an arrastre operator's duty is to take good care of the goods and to turn them over to the
party entitled to their possession. (Mindanao Terminal vs. Phoenix Assurance)

There is a distinction between an arrastre and a stevedore. [24] Arrastre, a Spanish word which refers to hauling of
cargo, comprehends the handling of cargo on the wharf or between the establishment of the consignee or shipper and the ship's
tackle. The responsibility of the arrastre operator lasts until the delivery of the cargo to the consignee. The service is usually
performed by longshoremen. On the other hand, stevedoring refers to the handling of the cargo in the holds of the vessel or
between the ship's tackle and the holds of the vessel. The responsibility of the stevedore ends upon the loading and stowing of
the cargo in the vessel.

It is not disputed that Mindanao Terminal was performing purely stevedoring function while the private respondent in
the Summa case was performing arrastre function. In the present case, Mindanao Terminal, as a stevedore, was only charged
with the loading and stowing of the cargoes from the pier to the ships cargo hold; it was never the custodian of the shipment of
Del Monte Produce. A stevedore is not a common carrier for it does not transport goods or passengers; it is not akin to a
warehouseman for it does not store goods for profit. The loading and stowing of cargoes would not have a far reaching public
ramification as that of a common carrier and a warehouseman; the public is adequately protected by our laws on contract and
on quasi-delict. The public policy considerations in legally imposing upon a common carrier or a warehouseman a higher degree
of diligence is not present in a stevedoring outfit which mainly provides labor in loading and stowing of cargoes for its clients.
(Mindanao Terminal vs. Phoenix Assurance)

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