Facts:

• Champion Auto Supply Co., Inc. (plaintiff-appellant) vs. Bureau of Customs (defendant-appellee).
• On March 24, 1964, the vessel "Siquijor" delivered three cases of U.S. Army Foreign Excess Property-Gears from Yokohama, Japan, to the Bureau of Customs in Manila.
• The Bureau of Customs acted as the arrastre operator responsible for the custody and delivery of the goods to Champion Auto Supply Co., Inc.
• Upon delivery, the consignee found the three cases empty, with contents valued at P15,499.49 missing.
• Champion Auto Supply Co., Inc. filed a suit on October 8, 1964, seeking recovery of the lost goods' value and attorney's fees of P3,850.00.
• The Court of First Instance of Manila dismissed the case on July 28, 1965, ruling that the Bureau of Customs, as an agency of the Republic, lacks a separate legal personality and cannot be sued without consent.
• Champion Auto Supply Co., Inc. appealed the decision.

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed the lower court's decision, ruling that the Bureau of Customs cannot be sued for claims arising from its arrastre operations, as these are governmental duties.
• The Court noted that the fixed money claim co...(Unlock)

Ratio:

• The Supreme Court's ruling is based on the principle that the Bureau of Customs, as an agency of the Republic, does not have a separate legal personality allowing it to be sued without state consent.
• This aligns with the doctrine of state immunity, which protects the government from lawsuits without permission.
• The Court referenced Mobil Philippines Exploration, Inc. v. Customs Arrastre Service and Bureau of Customs, establ...continue reading