Case Digest (G.R. No. 84607)
Facts:
Republic of the Philippines v. Hon. Edilberto G. Sandoval; Erlinda C. Caylao, et al., G.R. Nos. 84607 and 84645, March 19, 1993, the Supreme Court En Banc, Campos, Jr., J., writing for the Court.Petitioners in G.R. No. 84645 were the heirs of deceased rallyists and sixty-two injured victims (the Caylao group), who filed a complaint for damages arising from the Mendiola incident of January 22, 1987 (the Mendiola massacre). Respondents in the lower court included the Republic of the Philippines and numerous military and police officers and personnel impleaded in their official and personal capacities. In G.R. No. 84607 the Republic (with the same impleaded officers) sought relief against the trial court order that dismissed the complaint as to the Republic.
The factual background: the Kilusang Magbubukid sa Pilipinas (KMP) encamped at the Ministry of Agrarian Reform and later marched toward Malacañang on January 22, 1987 to press agrarian reform demands. Government crowd-dispersal forces — Western Police District (WPD) CDC units, INP Field Force contingents, and Marine Civil Disturbance Control (CDC) units — were deployed under OPLAN YELLOW. Clash occurred at Mendiola: the Citizens’ Mendiola Commission (created by Administrative Order No. 11) found that stones, pillboxes and other weapons were thrown, the government line was breached, shots were fired (origin unclear), and that twelve marchers were killed with many others wounded; the Commission recommended criminal investigations of unidentified shooters, administrative sanctions for certain commanders, and that the government compensate the deceased and wounded.
After a formal demand for indemnification (July 27, 1987) and indorsement to DBM, petitioners filed Civil Case No. 88-43351 in the Regional Trial Court, Branch 9, Manila on January 20, 1988. On February 23, 1988 the Solicitor General moved to dismiss the complaint as to the Republic for want of the State’s consent to suit. Respondent Judge Edilberto G. Sandoval granted the motion as to the Republic in an Order dated May 31, 1988 and denied reconsideration on August 8, 1988; the judge denied dismissal as to the individual officers and retained the action against them. The Caylao group sought relief from those orders under Section 1, ...(Subscriber-Only)
Issues:
- Did the State waive its sovereign immunity so that the Republic of the Philippines may be held civilly liable for deaths and injuries resulting from the Mendiola incident?
- If the State did not waive immunity, may the military and police officers and personnel be held personally liable for acts that exceeded their authority d...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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