Case Digest (G.R. No. L-20063)
Facts:
- The case involves Philippine Resources Development Corporation (petitioner) against the Republic of the Philippines, Macario Apostol, and Empire Insurance Company (respondents).
- In 1951, Macario Apostol contracted with the Bureau of Prisons to purchase almaciga and 3,000,000 board feet of lauan logs for P88.00 per thousand board feet.
- Apostol posted a performance bond of P10,000.00 with Empire Insurance Company as surety.
- The Bureau of Prisons delivered the logs and almaciga, but Apostol failed to pay the full amount, leaving an outstanding balance of P34,015.06.
- To settle the debt, Apostol delivered materials valued at P30,436.94, but the Bureau of Prisons did not credit this due to lack of documentation.
- On May 6, 1955, the Republic filed a complaint against Apostol and Empire Insurance Company for the outstanding amount.
- Apostol claimed to have settled his account in kind and admitted to a remaining balance of P758.12.
- Empire Insurance Company filed a cross-claim against Apostol and his co-maker, Arsenio Afan.
- The Philippine Resources Development Corporation sought to intervene, claiming ownership of the delivered materials, but the trial court denied this motion.
- The Court of Appeals reversed the trial court's decision, allowing the intervention, which was affirmed by the Supreme Court.
- The trial court ruled in favor of the Republic, ordering Apostol to pay the outstanding amount and absolving Empire Insurance Company.
- Both the Republic and Apostol appealed, leading to a modified decision by the Court of Appeals.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the Republic of the Philippines is immune from suit in this case, as the complaint in intervention was directed against Macario Apostol, not the Republic.
- The dismissal of the complaint in intervention against Macario Apostol was set aside, allowing the P...(Unlock)
Ratio:
- The Supreme Court emphasized the principle of state immunity from suit, stating that a claim cannot be maintained against the State without its consent.
- The Court cla...continue reading
Case Digest (G.R. No. L-20063)
Facts:
The case involves the Philippine Resources Development Corporation (petitioner) against the Republic of the Philippines, Macario Apostol, and Empire Insurance Company (respondents). The events leading to the case began in 1951 when Macario Apostol entered into a contract with the Bureau of Prisons to purchase almaciga and 3,000,000 board feet of lauan logs at a price of P88.00 per thousand board feet. To secure his obligation, Apostol posted a performance bond of P10,000.00 with Empire Insurance Company as surety. The Bureau of Prisons delivered the logs and almaciga to Apostol; however, he failed to pay the full amount due, resulting in an outstanding balance of P34,015.06.
To settle this debt, Apostol delivered various materials, including 892 pieces of GI sheets, 399 GI pipes, and 2,793 pieces of black iron sheets, valued at a total of P30,436.94. However, due to a lack of supporting documentation, the Bureau of Prisons did not credit this amount against Apostol's debt. On May 6, 1955, the Republic of the Philippines filed a complaint in the Court of First Instance of Manila against Apostol and Empire Insurance Company for the collection of the outstanding amount. Apostol claimed to have settled his account in kind and admitted to a remaining balance of P758.12.
Empire Insurance Company filed a cross-claim against Apostol and his co-maker, Arsenio Afan. The Philippine Resources Development Corporation, of which Apostol was president, sought to intervene in the case, claiming ownership of the materials delive...