Case Digest (G.R. No. L-35645) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 221 Phil. 179 (1985), the petitioners are the United States of America, Capt. James E. Galloway, William I. Collins, and Robert Gohier, all officers of the U.S. Navy’s Engineering Command. The respondents are Hon. V. M. Ruiz, Presiding Judge of Branch XV, Court of First Instance of Rizal, and Eligio de Guzman & Co., Inc. In May 1972, the U.S. Naval Station at Subic Bay invited bids for shore-repair projects. Eligio de Guzman & Co. submitted bids and responded to U.S. requests for confirmation of its proposals and bonding information. In June 1972, the company received a letter signed by petitioner Collins rejecting its bid due to an allegedly poor performance rating on a prior contract and advising that awards were made to others. The company then filed Civil Case No. 779-M in the defunct Court of First Instance of Rizal against the United States and the individual officers, seeking specific performance of the contract or damages, and a writ of preliminary injunction to enjoi Case Digest (G.R. No. L-35645) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and contractual dealings
- At relevant times, the United States maintained a naval base in Subic, Zambales under the RP-US Military Bases Agreement.
- In May 1972, the U.S. Naval Station at Subic Bay invited bids for wharf and shoreline repair projects.
- Eligio de Guzman & Co., Inc. submitted bids and confirmed its price proposals and bonding company as requested by U.S. agents.
- Award denial and subsequent suit
- In June 1972, William I. Collins, acting for the U.S. Navy, notified Eligio de Guzman & Co., Inc. that it was disqualified for unsatisfactory past performance and that contracts were awarded to third parties.
- The company filed Civil Case No. 779-M in the CFI of Rizal, seeking specific performance or damages and a preliminary injunction to enjoin contracts with third parties.
- Petitioners (the United States and its agents) entered a special appearance to challenge jurisdiction on grounds of foreign sovereign immunity, then moved to dismiss and opposed injunctive relief.
- The trial court denied the motion to dismiss, issued the preliminary injunction, and denied two motions for reconsideration, prompting this petition for certiorari.
Issues:
- Jurisdictional scope of Philippine courts over foreign sovereigns
- Can the Republic of the Philippines’ courts entertain a suit against the United States and its agents absent express consent?
- Nature of the contested contracts
- Whether contracts to repair Subic Bay naval facilities are sovereign (jure imperii) or commercial (jure gestionis) acts for state-immunity purposes.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)