G.R. No. 90314 - Shauf vs. Court of Appeals

Clark Air Base was established under the 1947 Philippines–U.S. Military Bases Agreement.
The Third Combat Support Group maintained:

A Central Civilian Personnel Office (CCPO) headed by the civilian personnel officer (Detwiler) responsible for all civilian personnel administration.
An Education Branch under the education director (Persi) tasked with academic and vocational guidance for military dependents.

Loida Q. Shauf, a Filipino national married to a U.S. Air Force member, applied in October 1976 for the vacant GS-1710-9 Guidance Counselor position.

She held an MA, completed extensive coursework toward a PhD, was civil service eligible, and had four years’ prior service in the same role at Clark.

Persi reviewed the three local applications, questioned Shauf’s records (citing no folder at NPRC, USA), and returned all applications, requesting CORRO referrals.
CORRO selected Edward Isakson (U.S. mainland), placed on rolls January 1977 despite non-compliance with GS-1710-9 requirements.

Rudolph Duncan’s report (Feb 1977) found Shauf “highly qualified” and Persi’s process irregular.
A “Notice of Proposed Disposition” (May 1977) recommended a 180-day overhire for Shauf with promise of permanent appointment, contingent on vacancy.
Respondents extended incumbent Abalateo’s term, barring Shauf’s appointment; disregarded U.S. Civil Service Commission’s order to remove Isakson.

Shauf filed a discrimination suit in the Regional Trial Court (RTC), Branch LVI, Angeles City (Civil Case No. 2783), alleging nationality and sex discrimination by Detwiler and Persi.
Respondents moved to dismiss citing U.S. sovereign and official immunity; RTC denied the motion.
Parties stipulated facts, including Shauf’s qualifications and the applicable DODI and Air Force regulations favoring local dependents.
RTC rendered judgment (March 8, 1988) awarding Shauf actual damages of US $39,662.49, moral and exemplary damages of ₱100,000, attorney’s fees of 20%, and costs.
Both sides appealed to the Court of Appeals (CA-G.R. CV No. 17932). The CA reversed, dismissed the complaint, and denied reconsideration.

Whether respondents, as U.S. military officials, are immune from suit in Philippine courts under sovereign-immunity principles and the Military Bases Agreement.

Whether Detwiler and Persi unlawfully discriminated against Shauf on account of her nationality, sex, and color.

Whether Shauf’s failure to exhaust U.S. administrative or federal court remedies bars her Philippine action.
Whether Philippine courts have jurisdiction over actions involving U.S. military personnel and U.S. federal civil-service matters.

Whether the award of actual, moral, exemplary damages, and attorney’s fees by the RTC was proper and supported by evidence.