Case Digest (G.R. No. 250763)
Facts:
Matthew Westfall v. Maria Carmela D. Locsin, Amy Leung, Noriko Ogawa, Gil‑Hong Kim, Diwesh Sharan, Ramesh Subramaniam, Ken L. Chee, Bibiana Victoria G. Francisco, Takehiko Nakao, Toshio Oya, Makoto Kubota, Christopher Stephens, Ramit K. Nagpal, and Deborah Stokes, G.R. No. 250763, April 16, 2024, the Supreme Court En Banc, Zalameda, J., writing for the Court.Petitioner Matthew Westfall, a former staff member of the Asian Development Bank (ADB), filed a Complaint for damages alleging that members of the ADB Screening Committee (the Screening Committee or SC) — principally Maria Carmela D. Locsin and other respondents (collectively, Locsin et al.) — made abusive and defamatory statements in the VP Panel Notes and the Interview Report during ADB’s selection process for a Technical Advisor position; Westfall also filed a criminal libel complaint and exhausted ADB’s internal grievance and appeal processes (the Appeals Committee ultimately ruled in his favor administratively).
At trial, Branch 138, Regional Trial Court (RTC), Makati City, dismissed Westfall’s complaint on the ground that Locsin et al., as ADB officers, enjoyed immunity from suit for acts performed in their official capacity; the RTC also dismissed claims against several other ADB officers (Nakao et al.) for failure to state a cause of action. The RTC denied Westfall’s motion for reconsideration. On certiorari, the Court of Appeals (CA) denied Westfall’s petition, holding that whether Locsin et al. acted in their official capacity was a question of fact and that the evidence showed they acted within their authority; it likewise affirmed dismissal as to Nakao et al.
Westfall filed a Petition for Review on Certiorari with the Supreme Court. In a Resolution dated April 27, 2022, this Court partly granted the petition: it reinstated Westfall’s civil complaint and remanded the case to the trial court to determine whether certain respondents were acting in their official capacities (and thus entitled to functional/diplomatic immunity), while affirming dismissal as to Nakao et al. Locsin et al. filed a Motion for Partial Reconsideration Ad Cautelam with Motion to Refer the Case to the Court En Banc and Set the Case for Oral Arguments, arguing (inter alia) that the Court should decide the legal question itself (no factua...(Pro-only)
Issues:
- Should the Motion to refer the case to the Court En Banc and to set the case for oral arguments be granted?
- Did the Court err in remanding the case to the RTC for further proceedings on the applicability of functional immunity?
- Were the acts complained of performed by Locsin et al. in their official capacities and therefore covered by functional immunity (i.e., were the statements ultra...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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