Case Digest (G.R. No. L-24005)
Facts:
- In the consolidated cases of Universal Mills Corporation v. Bureau of Customs and Fireman's Fund Insurance Company v. Republic of the Philippines and Bureau of Customs, the plaintiffs sought to recover damages for lost or damaged goods.
- Universal Mills Corporation (plaintiff-appellant) filed a case against the Bureau of Customs and/or the Customs Arrastre Service (defendants-appellees) to recover P5,130.69 for damages to goods consigned to them and discharged at the Port of Manila from the vessel SS Pioneer Mist on April 10, 1963.
- The goods were found to be either empty or partially spilled.
- The Court of First Instance of Manila dismissed the complaint, citing lack of jurisdiction and the non-suability of the government.
- Fireman's Fund Insurance Company (plaintiff-appellant), as subrogee of General Electric Company (Philippines), Inc., sought to recover P487.23 for a missing video cone consigned to General Electric and discharged at the Port of Manila from the vessel SS Pioneer Main on August 19, 1963.
- The City Court of Manila ruled in favor of the plaintiff, but the Court of First Instance of Manila dismissed the complaint on appeal, also citing the non-suability of the government.
- Both plaintiffs appealed the dismissals.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the Bureau of Customs and the Customs Arrastre Service cannot be sued without the consent of the State.
- The Court held that the handling of arrastre operations by the Bureau of Customs is a necessary incident to its primary governmental function and does not negate the government's immunity from suit.
- The Court affirmed that the inclusion of the Republic of the Philippines as a defendant would not offset the non-...(Unlock)
Ratio:
- The Supreme Court's decision was based on the principle of state immunity from suit, which is well-established in Philippine jurisprudence.
- The Court emphasized that the Bureau of Customs and the Customs Arrastre Service are government offices and, as such, cannot be sued without the State's consent.
- The Court rejected the plaintiffs' argument that the Bureau of Customs acted...continue reading
Case Digest (G.R. No. L-24005)
Facts:
In the consolidated cases of Universal Mills Corporation v. Bureau of Customs and Fireman's Fund Insurance Company v. Republic of the Philippines and Bureau of Customs, the plaintiffs sought to recover damages for lost or damaged goods. Universal Mills Corporation (plaintiff-appellant) filed a case against the Bureau of Customs and/or the Customs Arrastre Service (defendants-appellees) to recover P5,130.69 for damages to goods consigned to them and discharged at the Port of Manila from the vessel SS Pioneer Mist on April 10, 1963. The goods were found to be either empty or partially spilled. The Court of First Instance of Manila dismissed the complaint, citing lack of jurisdiction and the non-suability of the government. Fireman's Fund Insurance Company (plaintiff-appellant), as subrogee of General Electric Company (Philippines), Inc., sought to recover P487.23 for a missing video cone consigned to General Electric and discharged at the Port of Manila from the vessel SS Pioneer Main on August 19, 1963. The City Court of Manila ruled in favor of the plaintiff, but the Court of First Instance of Manila dismissed the complaint on appeal, also citing the non-suability of the government. Both plaintiffs appealed the dismissals.
Issue:
- Can the Bureau of Customs and the Customs Arrastre Service be sued without the consent of the State?
- Does the handling of arrastre operations by the Bureau of Customs constitute a proprietary function that would negate the government's immunity...