Administrative Law

Case Digest
Republic of the Philippines
SUPREME COURT
Manila

G.R. No. 90482 August 5, 1991

REPUBLIC OF THE PHILIPPINES, acting through the SUGAR REGULATORY

ADMINISTRATION, and REPUBLIC PLANTERS BANK, petitioners,
vs.
THE HONORABLE COURT OF APPEALS, 15th Division, THE HONORABLE CORONA
IBAY-SOMERA, in her official capacity as Presiding Judge of the Regional Trial Court,
National Capital Region, Branch 26, Manila, JORGE C. VICTORINO and JAIME K. DEL
ROSARIO, in their official capacities as RTC Deputy Sheriffs of Manila, ROGER Z.
REYES, ERNESTO L. TREYES, JR., and EUTIQUIO M. FUDOLIN, respondents.

Enrique V. Olmedo for Independent Sugar Farmers, Inc.

Reyes, Treyes & Fudolin Law Firm for respondents.

DAVIDE, JR., J.:

FACTS:
 On May 16, 1986, Republic Planters Bank (RPB) and others filed a complaint
against the Philippine Sugar Commission (PHILSUCOM) and the National Sugar
Trading Corporation (NASUTRA) in RTC Branch 26.
 The complaint sought various actions, including the delivery of sugar stocks,
payment of interests, damages, and attorney's fees.
 PHILSUCOM was replaced by the Sugar Regulatory Administration (SRA)
through Executive Order No. 18, but it was allowed to continue as a juridical
entity for three more years for legal matters.
 The Office of the Government Corporate Counsel (OGCC) filed an appeal on
behalf of the Republic of the Philippines through SRA and RPB.
 The Court of Appeals dismissed the petition, primarily because SRA lacked the
power to represent the Republic of the Philippines in this case, and OGCC could
not represent SRA.

ISSUES:
1. Whether the SRA had the authority to represent the Republic of the Philippines.
2. Whether OGCC could represent SRA.
3. Whether RPB had standing to question attorney's fees.
4. Whether the judge violated a temporary restraining order (TRO)
RULINGS:
1. SRA lacked the authority to represent the Republic of the Philippines in this case
because its charter did not grant it the power to do so.
2. OGCC could not represent SRA since it did not have the authority to represent
government-owned or controlled corporations like SRA, and the alleged
authorization by the President was based on an erroneous interpretation of the
law
3. RPB, being a government-owned corporation, could legally be represented by
OGCC, but it could not question the right of private respondents to attorney's
fees since it had accepted the role of Trustee and received benefits as such.
4. The judge did not violate the TRO, as her actions were motivated by a desire to
preserve and protect public funds, and no malice or damage to the petitioners'
rights was demonstrated.

RATIONALE:
In Republic of the Philippines v. The Honorable Court of Appeals et al. (G.R. No. 90482,
August 5, 1991), the Supreme Court ruled that the Sugar Regulatory Administration
(SRA) did not possess the legal authority to represent the Republic of the Philippines in
the case due to limitations in its charter. The Office of the Government Corporate
Counsel (OGCC) could not represent the SRA, as it lacked the statutory authority to do
so. Additionally, Republic Planters Bank (RPB) could not contest the attorney's fees
since it had accepted the role of Trustee and benefited from it.

Regarding the alleged violation of a temporary restraining order (TRO) by the presiding
judge, the Court found her actions to be motivated by a desire to safeguard public funds
and ruled in her favor. Consequently, the petition was denied for lack of merit, and the
petitioners were ordered to bear the costs of the case. This case underscored the
importance of government agencies operating within their legally defined roles and
limitations.

Reference: https://lawphil.net/judjuris/juri1991/aug1991/gr_90482_1991.html