Short answer. By default, your statement as the depositor is accepted, since the forcible opening is attributable to the depositary — but only absent proof to the contrary, and the court may still weigh your credibility about the value you claim.
What the law says
As regards the value of the thing deposited, the statement of the depositor shall be accepted, when the forcible opening is imputable to the depositary, should there be no proof to the contrary.
Civil Code, Article 1981 — Sealed Deposits. Read the full provision →
Fault for the broken seal is presumed against the depositary
Article 1981 starts from a strong presumption. When something is deposited closed and sealed, the depositary must return it in that same condition, and is liable for damages if the seal or lock is broken through their fault. Critically, fault on the part of the depositary is presumed, unless there is proof to the contrary — so the depositary, not you, carries the burden of showing the forced opening was not their doing.
Your valuation is accepted by default
Once the forcible opening is attributable to the depositary, Article 1981 answers your exact question: the statement of the depositor — you — shall be accepted as to the value of the thing deposited, should there be no proof to the contrary. This is a deliberate default in the depositor's favor, because the depositary's own breach of the seal is what makes independent verification of the contents difficult in the first place.
This default is not unchallengeable
The article immediately qualifies the rule: the courts may pass upon the credibility of the depositor with respect to the value claimed by him. So while your statement is accepted as the default position, it is not treated as automatically conclusive — a court can still assess whether your claimed value is credible, and evidence that contradicts your valuation can defeat it, particularly if the claimed value seems inflated compared to what a reasonable person would expect to store in that kind of container.
The depositary's duty of secrecy survives the breach
Article 1981 also addresses what happens to the depositary's obligations after the seal is broken, whether or not the depositary was at fault. In either case, the depositary shall keep the secret of the deposit. Breaking the seal, even without fault, does not release the depositary from the underlying duty not to disclose what the deposit contained or revealed, and that duty persists for as long as the deposit relationship itself continues.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Marina Port Services vs. American Home Assurance Corporation, G.R. No. 201822, August 12, 2015 — read the decision on LawPhil →