Title
Philippine Racing Club, Inc. vs. Bonifacio
Case
G.R. No. L-11944
Decision Date
Aug 31, 1960
A 1950 horse race at Santa Ana Hippodrome was canceled due to a faulty start, leading to financial losses. The Philippine Racing Club sued the Commission on Races for damages, but the Supreme Court ruled the respondents acted in good faith and were immune from liability.

Case Digest (G.R. No. L-11944)
Expanded Legal Reasoning Model

Facts:

On July 23, 1950, a horse race at the Santa Ana Hippodrome organized by the Philippine Racing Club, Inc. was marred by a faulty start. As the horses stalled, one turned around and blocked three others on its left, prompting the official starter to signal that the race should be cancelled. However, when he attempted to notify the stewards/judges—Carlos Coscolluela and Melquiades Parungao—he was dismissed, with one telling him to “shut up.” Consequently, the race was allowed to proceed, and winners were declared with corresponding dividends paid out. The public, aggrieved by the outcome in light of the bad start, initiated a commotion that reached the Commission on Races. This commission, composed of members including Arsenio Bonifacio, promptly conducted an on-the-spot investigation, determined that the race had indeed started faultily, and announced its cancellation. However, because many ticket holders had already cashed their winning tickets, the club was forced to refund the losing bets amounting to P5,032.00. Plaintiffs then filed suit alleging that the defendants—members of the Commission on Races—had acted beyond their authority, thereby causing moral damages by tarnishing their reputation. After a controversial decision at the trial level (which found for the plaintiffs) and a reversal by the Court of Appeals, the case was elevated for review.

Issues:

  • Whether the action of the Board of Stewards in refusing to cancel the race, despite the official starter’s recommendation, barred the Commission on Races from later annulling the race.
  • Whether the Commission on Races exceeded its lawful authority by annulling a race in which the board of judges had already rendered a final and unappealable decision.
  • Whether the respondents (acting in their official capacity) can be held liable for damages despite the alleged excess in authority, considering the doctrine of acting in the line of duty and under color of authority.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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