Case Digest (G.R. No. 9596)
Facts:
- The case MARCOS MENDOZA vs. FRANCISCO DE LEON ET AL. was decided on February 15, 1916, by the Supreme Court of the Philippines.
- Plaintiff Marcos Mendoza filed for damages against the municipal council members of Villasis, Pangasinan.
- The dispute involved the revocation of Mendoza's lease for an exclusive ferry privilege granted under Act No. 1634.
- Mendoza operated the ferry for over a year before being forcibly ejected based on a council resolution that awarded the franchise to another individual.
- The municipal council had both governmental and corporate functions, including managing local utilities like ferries.
- Mendoza argued he had a vested right to operate the ferry for the lease's duration, claiming the council's actions breached the contract.
- The lower court ruled in favor of Mendoza, prompting an appeal from the defendants.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the individual members of the municipal council are jointly and severally liable for the damages sustained by Mendoza due to the wrongful rescission of his ferry lease.
- The Court found that the municipal counc...(Unlock)
Ratio:
- The Supreme Court emphasized the distinction between the governmental and corporate functions of municipalities.
- Municipalities enjoy immunity for acts performed in their governmental capacity but are liable for actions taken in their corporate capacity, especially regarding contracts.
- The leasing of a municipal ferry is considered a corporate function, and Mendoza had a vested right to operate it under his lease terms.
- The councilors' actions in ejecting Mendoza were unjustifiable due to the lack of valid reasons for the lease's revocation....continue reading
Case Digest (G.R. No. 9596)
Facts:
The case of MARCOS MENDOZA vs. FRANCISCO DE LEON ET AL. was decided on February 15, 1916, by the Supreme Court of the Philippines. The plaintiff, Marcos Mendoza, filed an action for damages against the individual members of the municipal council of Villasis, Pangasinan. The dispute arose from the revocation of a lease for an exclusive ferry privilege that had been duly awarded to Mendoza under Act No. 1634 of the Philippine Commission. After utilizing the ferry for a little over a year, Mendoza was forcibly ejected from the ferry service based on a resolution adopted by the defendants, which awarded the same ferry franchise to another individual. The municipal council, acting under the Municipal Code, had both governmental and corporate functions, which included the management of local utilities such as ferries. Mendoza contended that he had a vested right to operate the ferry for the duration of his lease, and the council's actions constituted a breach of contract. The lower court ruled in favor of Mendoza, leading to the appeal by the defendants.
Issue:
- Are the individual members of the municipal council personally liable for the damages sustained by Mendoza due to the revocation of his ferry lease? ...