Animos v PVAO

Facts: Isidro Animos, one of the petitioners, was a veteran. According to RA 65,
those who sustained injuries in line of duty, shall be given a life pension. Animos
filed before the respondent a claim for maximum pension benefits. He was only
awarded an amount tantamount to his allegedly disability rate. RTC held that the
claim is a money claim against the Government over which it did not have
jurisdiction. CA sustained the RTC decision.

Issue: WON the money claim should not prosper

Ruling: No. The doctrine of non-suability of the State cannot be invoked where
the suit against a public functionary had to be instituted because of his failure to
comply with the duty imposed by statue appropriating public funds for the
benefit of plaintiff or petitioner.

USA v Reyes

Facts: Private respondent was the only one searched by private petitioner – a
manager of the US Navy Exchange Branch at the Joint United States Military
Assistance Group (NEX-JUSMAG) outside the said establishment when the
former went shopping, thus since the said act could have been motivated by
speculations of theft, shoplifting and such other wrong doings which caused the
private respondent undue embarrassment and indignity, private respondent
prayed for judgment ordering private petitioner P600,000 for moral and
exemplary damages.

Issue: WON Private Petitioner is immune to suits as a manager of the US navy

Exchange Branch at the headquarters of JUSMAG, under the Philippines-US
Military Assistance Agreement of 1947 and Military Bases Agreement of 1947.

Ruling: Yes. Bradford was a civilian employee since according to Article 16(b) of
the 1953 Military Assistance Agreement creating the JUSMAG – only the Chief of
the Military Advisory Group and not more than six (6) other senior members
designated by the Chief will be accorded diplomatic immunity, also, the
challenged act was committed outside the US Military Bases. Bradford was sued
in her private or personal capacity for acts allegedly done beyond the scope and
even beyond her place of official functions. The case falls within the exception of
the doctrine of State Immunity. Also, Bradford is not among those granted
diplomatic immunity under Article 31 Vienna Convention on Diplomatic
Relations: That an action of public functionary relating to any professional or
commercial activity exercised by the diplomatic agent in receiving State outside
his official function is not one of those immune from suits.
Lansang v CA

Facts: Amado J. Lansang, petitioner, as Chairman of the National Parks

Development Committee, ordered the vacation of a the kiosks of a public park
where the private respondents are operating their business. Private respondent
filed an action for damages, alleging that the petitioner abused his authority.
Petitioner, on the other hand, argued that the complaint filed against him is
actually against the State, which could not prosper without its consent, and that
NPDC is a government agency, and that when he ordered the eviction of the
private respondents, he was acting in his capacity as the NPDC chairman.
Issue: WON petitioner is immune from the instant case
Ruling: No. The petitioner is being sued not on his capacity as NPDC Chairman
but in his personal capacity when he allegedly had personal motives in ordering
the ejectment. The complaint filed by the private respondents merely identified
petitioner as Chairman of NPDC but did not categorically state that he is being
sued in that capacity.

Shauf v CA

Facts: Petitioner was allegedly discriminated by the private respondents who

were officers of the US Armed Forces when the former applied for a position as a
Guidance Counselor at the Clark Air Base by reason of her nationality and sex.
Petitioner filed a complaint for damages.
Issue: WON private respondents are immune from the instant suit
Ruling: No. Private respondents were being sued in their private capacity for
discriminatory acts performed beyond their authority, hence the instant action is
not a suit against the United States Government which would require its consent.
While the doctrine appears to prohibit only suits against the state without its
consent, it is also applicable to complaints filed against officials of the state for
acts allegedly performed by them in the discharge of their duties. But it is a
different matter where the public official is made to account in his capacity as
such for acts contrary to law and injurious to the rights of plaintiff. The rationale
for this ruling is that the doctrine of state immunity cannot be used as an
instrument for perpetrating an injustice.
Republic v Sandoval

Facts: Private Respondents held a rally and marched toward Malacanang, they
were met by anti-riot squad. Clash occurred, and borrowing the words of the
Commission “pandemonium broke loose”. After the clash, twelve marchers were
officially confirmed dead, some wounded by gunshots and others sustained
minor injuries. Private respondents filed a complaint for damages against herein
petitioner.
Issue: WON the instant case should prosper
Ruling: The case does not qualify as a suit against the State. Some instances when
a suit against the State is proper are:
1. When the Republic is sued by name
2. When the suit is against an incorporated government agency
3. When the, suit is on its face against a government officer but the case is
such that ultimate liability will belong not to the officer but to the
government.
While the Republic in this case is sued by name, the ultimate liability does not
pertain to the government. Although the military officers and personnel, then
party defendants, were discharging their official functions when the incident
occurred, their functions ceased to be official the moment they exceeded their
authority.