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.
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Case Digest (G.R. No. L-26994)

Facts:

  1. Parties Involved:

    • Plaintiff-Appellee: Caltex (Philippines), Inc.
    • Defendants-Appellants: Customs Arrastre Service, Bureau of Customs, and/or Republic of the Philippines.
  2. 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.
  3. 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.
  4. 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:

  1. 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.
  2. 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)

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