Title
Mendoza vs. De Leon
Case
G.R. No. 9596
Decision Date
Feb 15, 1916
The municipal council's wrongful eviction and lease rescission lead to personal liability for its members and damages awarded to the plaintiff.
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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

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