G.R. No. L-28771 - Matabuena vs. Cervantes

M. H. Wylie, the assistant administrative officer at the U.S. Naval Base in Subic Bay.
Capt. James Williams, the commanding officer of the U.S. Naval Base in Subic Bay.

Aurora I. Rarang, an employee in the Office of the Provost Marshal assigned as a merchandise control guard, identified in the publication as “Auring.”

The Plan of the Day (POD) was a daily publication of the U.S. Naval Base aimed at disseminating important announcements and general instructions for military personnel.
A regular feature of the POD was the "NAVSTA ACTION LINE INQUIRY," which facilitated personnel reporting concerns or irregularities.
On February 3, 1978, the POD published an article under the “NAVSTA ACTION LINE INQUIRY” that alleged misconduct regarding the consumption of confiscated items by merchandise control personnel.
The article specifically mentioned “Auring” in a derogatory manner, accusing her of inappropriately consuming items like cigarettes and foodstuffs, and labeling her conduct as disgraceful to her division and the Office of the Provost Marshal.

Prior to publication, around three weeks before February 3, 1978, an inquiry suggesting the misconduct was received by M. H. Wylie and forwarded to the Provost Marshal’s office for comment.
The Provost Marshal’s office advised that if the article were to be published, the name “Auring” should be removed.
Despite this admonition, the name appeared in the final smooth copy of the POD, which was signed by M. H. Wylie, evidencing a failure to act on the recommendation.
Upon identifying the mistake, an apology letter was sent to Aurora I. Rarang on February 7, 1978.

Aurora I. Rarang initiated a damages action in the Court of First Instance (now the Regional Trial Court) of Zambales against M. H. Wylie, Capt. James Williams, and the U.S. Naval Base.
The allegations included claims of false, injurious, and malicious defamation amounting to libel, with repercussions to her honesty, virtue, reputation, and consequent exposure to public hatred, contempt, and ridicule.
The respondent sought monetary relief in moral damages, exemplary damages, and attorney's fees.

In response to the complaint, the defendants filed a motion to dismiss on the grounds of:

Immunity from suit arising from their official functions.
The U.S. Naval Base’s status as an instrumentality of a foreign government without proper consent to be sued.
Lack of jurisdiction over the subject matter and parties.

The acts of the petitioners were personal, tangent to their official functions, and hence, not attributable to the U.S. government.
The suit against the U.S. Naval Base was dismissed.
Judgment was rendered against the petitioners for moral damages, attorney's fees, and litigation expenses.

On appeal, the Intermediate Appellate Court (now Court of Appeals) modified the lower court’s monetary awards but essentially affirmed the trial court's findings regarding personal liability.
The petitioners appealed to the Supreme Court, which then reviewed the issues concerning immunity.

Whether M. H. Wylie and Capt. James Williams are immune from suit for actions taken in the publication of the POD, given that they performed their official duties at the U.S. Naval Base.
Whether the alleged actions in publishing a defamatory article, which implicated a private employee, fall within the ambit of their official functions or are considered personal and tortious.

Whether the U.S. Naval Base, as an instrumentality of a foreign state, can be subjected to suit without the consent of the United States.
Whether the principles set out in the RP-US Bases Treaty and customary international law extend immunity to the petitioners in cases involving alleged defamation and personal tort.

Whether acts committed while performing official duties can be excused if done under the guise of following orders, especially when such acts cause defamation.
Whether the petitioners’ failure to heed instructions (i.e., deleting the name “Auring”) transforms an official action into a personally actionable tort.