Case Digest (G.R. No. L-36084) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines v. Purisima, the Republic filed a petition for certiorari and prohibition against Hon. Amante P. Purisima, Judge of the Court of First Instance of Manila (Branch VII), and Yellow Ball Freight Lines, Inc. (“Yellow Ball”), stemming from Civil Case No. 79082, a money‐claim suit by Yellow Ball against the Rice and Corn Administration (“RCA”) for breach of contract. On September 7, 1972, RCA moved to dismiss for lack of jurisdiction, invoking the doctrine of non‐suability of the State. Despite the landmark decision in Mobil Philippines Exploration, Inc. v. Customs Arrastre Service (18 SCRA 1120) and more than fifty subsequent rulings reaffirming that a government entity cannot be sued without consent, Judge Purisima denied the motion on October 4, 1972. The Solicitor General then sought relief, arguing that the trial court’s order contravened Article XV, Section 16 of the 1973 Constitution, which expressly provides that “the State may not be sued withou Case Digest (G.R. No. L-36084) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- The Republic of the Philippines, through Solicitor General Mendoza, filed a petition for certiorari and prohibition.
- Respondents were Judge Amante P. Purisima of the CFI-Manila and Yellow Ball Freight Lines, Inc. in a civil action for money claims against the Rice and Corn Administration.
- Underlying Civil Suit and Motion to Dismiss
- Yellow Ball Freight Lines, Inc. sued the Rice and Corn Administration for breach of contract and recovery of freight charges.
- The Administration moved to dismiss on September 7, 1972, invoking the doctrine of non-suability of the State without its consent.
- Trial Court Action and Constitutional Basis
- On October 4, 1972, Judge Purisima denied the motion to dismiss and proceeded to assert jurisdiction.
- The 1973 Constitution (Art. XV, Sec. 16) expressly provides that “The State may not be sued without its consent.”
Issues:
- Sovereign Immunity
- Whether a court may entertain a private suit against a State agency or office in the absence of statutory consent.
- Jurisdictional Defect
- Whether the trial court’s denial of a motion to dismiss for lack of consent constitutes a grave abuse of discretion.
- Binding Effect of Contractual Consent
- Whether an agreement by counsel for a government agency to submit to suit is sufficient to waive immunity.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)