Case Digest (G.R. No. 159402)
Facts:
Air Transportation Office v. Spouses David and Elisea Ramos, G.R. No. 159402, February 23, 2011, Supreme Court Third Division, Bersamin, J., writing for the Court.
The petitioners are the Air Transportation Office (ATO); the respondents are Spouses David and Elisea Ramos (later substituted in part after David Ramos’s death). The Ramoses discovered that a 985-square-meter portion of their land (TCT No. T-58894, Baguio City) was being used as part of the runway and running shoulder of Loakan Airport, operated by the ATO. After negotiations, the parties executed a deed of sale dated August 11, 1995, whereby the Ramoses agreed to convey the affected portion to the ATO for P778,150.00; the ATO, however, failed to pay despite repeated demands.
On April 29, 1998 the Ramoses filed a collection action in the Regional Trial Court (RTC), Branch 61, Baguio City (Civil Case No. 4017‑R). In its answer the ATO and certain officials asserted as affirmative defenses that the parcel had been reserved under Proclamation No. 1358 and that the RTC lacked jurisdiction because the deed was entered into in the performance of governmental functions, invoking the State’s immunity from suit. The RTC denied the ATO’s motion for a preliminary hearing on that affirmative defense on November 10, 1998 and denied reconsideration on December 10, 1998.
The ATO sought certiorari in the Court of Appeals (CA) to annul the RTC’s interlocutory orders, but the CA dismissed the petition for certiorari for lack of grave abuse of discretion. On February 21, 2001 the RTC rendered judgment on the merits ordering the ATO to pay P778,150.00 with 12% annual interest from August 11, 1995, plus moral and exemplary damages (P150,000.00 each), attorney’s fees (P50,000.00 plus P15,000.00 for appearances), and costs. The ATO appealed to the CA; on May 14, 2003 the CA affirmed with modification, deleting costs, reducing moral and exemplary damages to P30,000.00 each, and attorney’s fees to P10,000.00.
The ATO filed a petition for review on ...(Pro-only)
Issues:
- May the Air Transportation Office be sued without the State’s consent? ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)