The Government of Philippine Islands vs El Monte de Piedad Y Caja de Ahorras de Manila

G.R. No. L-9959 December 13, 1916

FACTS:

About $400,000, were subscribed and paid into the treasury of the Philippine Islands by the inhabitants
of the Spanish Dominions of the relief of those damaged by the earthquake, which took place in the Philippine
Islands on June 3, 1863. Subsequent thereto a central relief board was appointed to distribute the moneys thus
voluntarily contributed and allotted $365,703.50 to the various sufferers named in its resolution. The
government used the money as such but $80,000 was left untouched and was thus invested to Monte de Piedad
bank, which was in turn invested as jewelries, equivalent to the same amount.

In June 1983, the Department of Finance called upon the same bank to return the $80,000 deposited from
before. The Monte de Piedad declined to comply with this order on the ground that the Governor-General of the
Philippine Islands and not the Department of Finance had the right to order the reimbursement because the
Philippine government is not the affected party. On account of various petitions of the persons, the Philippine
Islands brought a suit against Monte de Piedad for a recovery of the $80,000 together with interest, for the
benefit of those persons and their heirs. The defendant appealed and makes the following assignment of errors:

1. The court erred in not finding that the eighty thousand dollars ($80,000), give to the Monte de Piedad y Caja
de Ahorros, were so given as a donation subject to one condition, to wit: the return of such sum of money to the
Spanish Government of these Islands, within eight days following the day when claimed, in case the Supreme
Government of Spain should not approve the action taken by the former government.

2. The court erred in not having decreed that this donation had been cleared; said eighty thousand dollars
($80,000) being at present the exclusive property of the appellant the Monte de Piedad y Caja de Ahorros.

3. That the court erred in stating that the Government of the Philippine Islands has subrogated the Spanish
Government in its rights, as regards an important sum of money resulting from a national subscription opened
by reason of the earthquake of June 3, 1863, in these Island.

4. That the court erred in not declaring that Act Numbered 2109, passed by the Philippine Legislature on
January 30, 1912, is unconstitutional.

5. That the court erred in holding in its decision that there is no title for the prescription of this suit brought by
the Insular Government against the Monte de Piedad y Caja de Ahorros for the reimbursement of the eighty
thousand dollars ($80,000) given to it by the late Spanish Government of these Islands.

6. That the court erred in sentencing the Monte de Piedad y Caja de Ahorros to reimburse the Philippine
Government in the sum of eighty thousand dollars ($80,000) gold coin, or the equivalent thereof in the present
legal tender currency in circulation, with legal interest thereon from February 28th, 1912, and the costs of this
suit.

Issue:
Whether or not the Philippine government is authorized to file a reimbursement of the money of the
people deposited in the respondent bank.

Ruling:
Under the Principle of Parens Patriae, the Philippine Government being the guardian of the “rights of
the people” can represent the legitimate claimants of the beneficiary and therefore has the capacity to file a suit
against the appellant. The Philippine Government is not merely a nominal party that’s why it can bring and
prosecute this action by exercising its sovereign powers. The supreme court then held the right of the
government to file the case.

INTERNATIONAL SCHOOL ALLIANCE OF EDUCATORS (ISAE) vs. HON. LEONARDO A.

QUISUMBING in his capacity as the Secretary of Labor and Employment; HON. CRESENCIANO B.
TRAJANO in his capacity as the Acting Secretary of Labor and Employment; DR. BRIAN
MACCAULEY in his capacity as the Superintendent of International School-Manila; and
INTERNATIONAL SCHOOL, INC.,

G.R. No. 128845 June 1, 2000

FACTS:
International School Alliance of Educators (the School) hires both foreign and local teachers as members of its
faculty, classifying the same into two: (1) foreign-hires and (2) local-hires.

In which, the School grants foreign-hires certain benefits not accorded local-hires. These include housing,
transportation, shipping costs, taxes, and home leave travel allowance. Foreign-hires are also paid a salary rate
twenty-five percent (25%) more than local-hires. The School justifies the difference on two "significant
economic disadvantages" foreign-hires have to endure, namely: (a) the "dislocation factor" and (b) limited
tenure. The School explains:

1. A foreign-hire would necessarily have to uproot himself from his home country, leave his family and
friends, and take the risk of deviating from a promising career path — all for the purpose of pursuing his
profession as an educator, but this time in a foreign land. The new foreign hire is faced with economic
realities: decent abode for oneself and/or for one's family, effective means of transportation, allowance
for the education of one's children, adequate insurance against illness and death, and of course the
primary benefit of a basic salary/retirement compensation.
2. Because of a limited tenure, the foreign hire is confronted again with the same economic reality after his
term: that he will eventually and inevitably return to his home country where he will have to confront
the uncertainty of obtaining suitable employment after a long period in a foreign land.
3. The compensation scheme is simply the School's adaptive measure to remain competitive on an
international level in terms of attracting competent professionals in the field of international education.

The labor union and the collective bargaining representative of all faculty members of the School, contested the
difference in salary rates between foreign and local-hires. The Union claims that the point-of-hire classification
employed by the School is discriminatory to Filipinos and that the grant of higher salaries to foreign-hires
constitutes racial discrimination.

ISSUE:
Whether or not the Union can invoke the equal protection clause to justify its claim of parity.

RULING:
Hence, the Court finds the point-of-hire classification employed by respondent School to justify the distinction
in the salary rates of foreign-hires and local hires to be an invalid classification. There is no reasonable
distinction between the services rendered by foreign-hires and local-hires.