Case Digest (G.R. No. L-26994)
Facts:
The case involves Caltex (Philippines), Inc. as the plaintiff-appellee and the Customs Arrastre Service, Bureau of Customs, and the Republic of the Philippines as defendants-appellants. The events leading to the case began on March 31, 1965, when Caltex filed a complaint in the Court of First Instance of Manila. The plaintiff, as the consignee, sought to recover the value of eleven packages of assorted goods that had been discharged from a vessel and placed in the custody of the customs arrastre service operated by the Bureau of Customs. Caltex alleged that these eleven packages were missing, and the total value claimed was P10,682.66. However, after the filing of the complaint, subsequent deliveries were made, reducing the number of non-delivered packages to three, with a total value of P795.67. The lower court ruled in favor of Caltex, awarding the amount claimed with interest at the legal rate, despite the defendants' assertion of the State's immunity from suit. Th...
Case Digest (G.R. No. L-26994)
Facts:
Parties Involved:
- Plaintiff-Appellee: Caltex (Philippines), Inc.
- Defendants-Appellants: Customs Arrastre Service, Bureau of Customs, and/or Republic of the Philippines.
Nature of the Case:
- Caltex, as the consignee, filed a complaint on March 31, 1965, in the Court of First Instance of Manila to recover the value of eleven packages of assorted goods. These goods were discharged from a vessel into the custody of the Customs Arrastre Service, operated by the Bureau of Customs.
Allegations:
- Caltex claimed that eleven packages were missing. However, after filing the complaint, some packages were delivered, reducing the missing items to three, with a total value of P795.67.
Lower Court Decision:
- The Court of First Instance of Manila ruled in favor of Caltex, awarding the reduced amount of P795.67, with legal interest, despite the defendants' plea of state immunity from suit.
Issue:
Main Issue:
- Whether the Republic of the Philippines, through the Bureau of Customs, is immune from suit in its operation of the Customs Arrastre Service in the Port of Manila.
Sub-Issue:
- Whether the arrastre function, being proprietary in nature, waives the state's immunity from suit.
Ruling:
- The Supreme Court reversed the decision of the lower court and dismissed the complaint.
- The Court held that the Republic of the Philippines, through the Bureau of Customs, is immune from suit in its operation of the Customs Arrastre Service.
Ratio:
- (Unlock)