Title
Caltex , Inc. vs. Customs Arrastre Service
Case
G.R. No. L-26994
Decision Date
Nov 28, 1969
Caltex sued Customs Arrastre Service for missing goods; Supreme Court ruled state immunity applies, dismissing the claim as arrastre service is a governmental function.

Case Digest (G.R. No. L-26994)
Expanded Legal Reasoning Model

Facts:

  • Parties and Context
    • Plaintiff-Appellee: Caltex (Philippines), Inc., consignee of goods.
    • Defendants-Appellants: Customs Arrastre Service and/or Bureau of Customs and/or Republic of the Philippines.
    • The case arises from the operation of the customs arrastre service at the Port of Manila, which was then operated by the Bureau of Customs.
  • Cause of Action
    • On March 31, 1965, plaintiff filed an action in the Court of First Instance of Manila for recovery of the value of eleven packages of assorted goods said to be missing.
    • The total claimed value was P10,682.66.
    • Subsequent to filing, some packages were delivered, leaving only three packages undelivered, valued at P795.67.
  • Lower Court Decision
    • The trial court rendered judgment in favor of the plaintiff for the amount of P795.67 plus legal interest.
    • This decision was made notwithstanding the defendants’ plea of the State’s immunity from suit.
  • Appeal
    • Defendants appealed the decision to the Supreme Court.
    • The sole issue raised was the non-suability of the Republic with respect to its operation of the arrastre service through the Bureau of Customs.

Issues:

  • Whether or not the Republic of the Philippines can be sued in relation to the operation of the customs arrastre service through the Bureau of Customs.
  • Whether the operation of the arrastre service by the Bureau of Customs, albeit proprietary in nature, subjects the State to suit and liability.
  • What remedy is available to the plaintiff and similarly situated parties for claims arising from transactions involving the Bureau of Customs and arrastre services.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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