Wylie vs. Rarang

Facts:

In February 1978 M. H. Wylie was the Assistant Administrative Officer and Capt. James Williams the Commanding Officer of the U.S. Naval Station at Subic Bay; Aurora I. Rarang was a civilian employee assigned as merchandise control guard in the Office of the Provost Marshal. The station published a daily newsletter called the “Plan of the Day” (POD) which contained a recurring “NAVSTA ACTION LINE INQUIRY” feature. The POD published on February 3, 1978 an action-line item that (by name-calling “Auring”) accused a merchandise control inspector of appropriating confiscated items for personal consumption.

Rarangs identity as the “Auring” in the POD was established; Wylie later wrote her a letter of apology acknowledging inadvertent publication. Rarang sued in the Court of First Instance of Zambales for defamation/libel, seeking moral and exemplary damages and attorney’s fees, naming Wylie, Williams and the U.S. Naval Base as defendants. Defendants moved to dismiss on grounds of immunity: (1) Wylie and Williams acted in performance of official functions and thus were immune; (2) the U.S. Naval Base, as an instrumentality of the U.S. government, could not be sued without consent; and (3) lack of jurisdiction. The trial court denied the motion to dismiss.

The trial court found the acts of Wylie and Williams personal and tortious (not official acts imputable to the U.S. government), rendered judgment for plaintiff against the two officers for P100,000 moral/exemplary damages plus P30,000 attorney’s fees, and dismissed the suit as to the U.S. Naval Base. On appeal, the then Intermediate Appellate Court (now the Court of Appeals) modified the judgment to award P175,000 moral damages and P60,000 exemplary damages, and affirmed the rest; a motion for reconsideration was denied.

Petitioners brought the case to the Supreme Court by petition (the Court, in a resolution dated March 9, 1987, gave due course to the petition). Petitioners reiterated their claim of immunity as U.S. officers acting in official capacity and denied malicious intent; respondent maintained the act was tortious defamation. The Supreme Court considered prior jurisprudence on state immunity (including United States of America v. Guinto, Baer v. Tizon, United States of Americ...(Pro-only)

Issues:

• Are petitioners immune from suit by virtue of their status as United States naval officers and the rule of state immunity (including rights under the RP–US Bases Treaty and related precedent)?
• Did the POD publication constitute actionable defamation such that petitioners are personally liable for damages for negligence/ultra vires conduct?
• Was the U.S. Naval Base properly dismissed as a defendant o...(Pro-only)

Ruling:

• (Pro-only)

Ratio:

• (Pro-only)

Doctrine:

• (Pro-only)