G.R. No. 79253 - United States of America vs. Reyes

Nelia T. Montoya (private respondent) – American citizen employed as I.D. checker at the U.S. Navy Exchange (NEX) of the Joint U.S. Military Assistance Group (JUSMAG) in Quezon City; married to a Filipino-American U.S. serviceman.
Maxine Bradford (co-petitioner) – American citizen, activity exchange manager at NEX-JUSMAG; United States of America (public petitioner) invoked state immunity.

On 22 January 1987, Bradford ordered all JUSMAG employees’ purchases to be searched; Montoya alone was searched outside the store at the parking area, in presence of onlookers.
Montoya felt discriminated, alleging racial bias and excess of authority; she formally protested and, finding no policy basis for the search, filed a complaint for damages.

Montoya filed Civil Case No. 224-87 in RTC, Cavite, on 7 May 1987 seeking moral (₱500,000) and exemplary (₱100,000) damages plus attorney’s fees.
Summons served on Bradford on 13 May 1987; she obtained two extensions to answer but instead, with the U.S. government, moved to dismiss on grounds of sovereign and official immunity.
Montoya counter-moved for preliminary attachment; on 17 July 1987 the RTC denied the motion to dismiss and granted attachment upon bond. Writ issued 28 July 1987.
Neither Bradford nor the public petitioner moved for reconsideration; instead they filed a Rule 65 petition in the Supreme Court on 6 August 1987.

Bradford declared in default for failure to answer; Montoya presented ex-parte evidence.
RTC rendered judgment on 10 September 1987 awarding Montoya ₱300,000 moral damages, ₱100,000 exemplary damages, and ₱50,000 attorney’s fees; no costs.
Bradford and the U.S. government sought a temporary restraining order (TRO) from the Supreme Court; TRO issued 7 December 1987 enjoining execution.

Whether the complaint effectively sued the United States as a foreign sovereign without consent, violating state immunity.
Whether Bradford, as NEX-JUSMAG manager, is immune from suit for acts performed in official capacity under the 1947 Military Assistance and Bases Agreements.

Whether the search occurred outside the territorial scope of U.S. base control, thus falling within Philippine jurisdiction.
Whether Bradford’s acts were ultra vires—beyond her official authority—and therefore personal, not covered by immunity.