Case Digest (G.R. No. 250763) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 250763 decided April 16, 2024 (under the 1987 Constitution), petitioner Matthew Westfall, a former staff member of the Asian Development Bank (ADB), filed a complaint for damages against respondents Maria Carmela D. Locsin, Amy Leung, Noriko Ogawa, Gil-Hong Kim, Diwesh Sharan, Ramesh Subramaniam, Ken L. Chee, Bibiana Victoria G. Francisco, and others, all members or officers of ADB’s Screening Committee (SC). In early 2015 the SC reviewed Westfall’s application for a Technical Advisor position and prepared two confidential documents—the VP Panel Notes (Feb. 16, 2015) and an Interview Report—which contained mixed comments on his qualifications. Westfall alleged these statements were maliciously false, defamatory, and damaged his professional reputation. He also filed a criminal libel complaint. In defense, Locsin et al. invoked functional immunity, and certain respondents (Nakao et al.) argued the complaint failed to state a cause of action. On Aug. 17, 2017, RTC Bran Case Digest (G.R. No. 250763) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Petitioner Matthew Westfall, a former Asian Development Bank (ADB) staff member, applied for the position of Technical Advisor (Urban and Water). He was not shortlisted.
- Westfall alleged that members of the ADB Screening Committee, including respondents Locsin et al., made false and defamatory statements in two internal documents:
- VP Panel Notes (dated February 16, 2015), stating, among others, “Mr. Westfall has been away from the urban sector work for quite some time and he has not kept his knowledge current.”
- Interview Report, containing notes on Westfall’s interview performance.
- Procedural History
- Westfall exhausted ADB’s internal grievance process and filed (a) a criminal libel complaint and (b) a civil Complaint for Damages under Articles 19, 20, 21, and 33 of the Civil Code before RTC Makati (Branch 138).
- RTC Makati (August 17, 2017)
- Dismissed the Complaint against Locsin et al. on grounds of functional immunity for acts in official capacity.
- Dismissed the Complaint against Nakao et al. for failure to state a cause of action.
- Court of Appeals (April 22, 2019 Decision; November 26, 2019 Resolution)
- Denied Westfall’s Rule 65 petition; held immunity issue is factual.
- Affirmed RTC dismissal.
- Supreme Court (April 27, 2022 Resolution)
- Partly granted Westfall’s Petition for Review: reinstated his Complaint against Locsin et al. and remanded to trial court to determine official-capacity actions.
- Affirmed dismissal as to Nakao et al.
- Respondents filed Motion for Partial Reconsideration Ad Cautelam with Motion to Refer Case to the Court En Banc and Set for Oral Arguments.
Issues:
- Procedural Questions
- Should the case be referred to the Supreme Court En Banc?
- Should the Court set the case for oral arguments?
- Was the remand to the RTC for factual inquiry on official capacity erroneous?
- Merits Questions
- Did respondents act in their official capacities such that they enjoy ADB functional immunity?
- If so, do the alleged defamation or abusive statements constitute ultra vires acts (crimes) outside immunity?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)