Practice question
A bill merely lists an invoice number. There is no proof of incorporation of value details, notice of value to the carrier, or value-based freight. The shipper invokes Eastern Shipping Lines to claim automatic unlimited liability. Is that reasoning sound?
- No; the decision does not make a bare invoice number conclusive proof of a qualifying declaration.
- Yes; an invoice number always removes every limitation.
- Yes; the loss itself creates a pre-shipment declaration.
- No; invoices can never be incorporated by reference.
- No; declared value is legally irrelevant to COGSA.
Legal references
- Eastern Shipping Lines v. BPI/MS Insurance, G.R. No. 182864, January 12, 2015, main decision, COGSA Section 4(5): https://www.lawphil.net/judjuris/juri2015/jan2015/gr_182864_2015.html
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