Case Summary (G.R. No. L-8670)
Facts of the Case
On July 6, 1954, twenty employees at the Philippine Normal College (PNC), specifically working in various capacities within Normal Hall (as cooks, waiters, dishwashers, etc.), initiated a legal action in the Court of First Instance of Manila. They sought recovery of salary differentials and overtime pay against PNC, asserting their entitlements under employment law.
Procedural History
The Solicitor General, representing PNC, filed an answer denying liability on the part of the College. Prior to the case being tried on its merits, the court dismissed the lawsuit on the grounds that neither the Philippine Normal College nor the Philippine Normal School had the legal capacity to be sued, as they were not recognized as corporations or juridical entities. The plaintiffs' subsequent motion for reconsideration was denied, prompting an appeal to the Supreme Court.
Supreme Court's Rationale
Upon reviewing the appeal, the Supreme Court found merit in the claims made by the plaintiffs. The court referenced Republic Act No. 416, which transformed the former Philippine Normal School into the Philippine Normal College, granting it corporate powers as designated in Section 13 of the Corporation Law. This law allowed the PNC to govern its affairs and specified the power "to sue and be sued in any court." The court articulated that such an express grant of power negates any doubts regarding the College's legal capacity to be named a party in a lawsuit.
Governmental Instrumentality Argument
The Solicitor General contended that since the PNC functions as an instrumentality of the government, it could not be sued without the state's consent. However, the Supreme Court countered this argument by asserting that legislative intent was clear in granting the College the power to be sued. This was further supported by Section 6 of Republic Act No. 416, which stipulated that any legal process against the Board of Trustees must be served on the President or Secretary of the College, confirming its status as a
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Case Background
- On July 6, 1954, twenty employees of the Philippine Normal College, employed in various capacities such as cooks, waiters, and dishwashers in the dormitory known as Normal Hall, initiated legal proceedings.
- The plaintiffs sought recovery for salary differentials and overtime pay against the Philippine Normal College and/or the Philippine Normal School.
- The Solicitor General represented the defendants and filed an answer denying liability.
Initial Court Proceedings
- Before the merits of the case could be addressed, the Court of First Instance of Manila dismissed the case.
- The dismissal was based on the premise that neither of the defendants was a corporation or a juridical entity capable of being sued.
- A motion for reconsideration was filed but subsequently denied, prompting the plaintiffs to appeal the dismissal.
Appeal to the Supreme Court
- The plaintiffs claimed that the dismissal of their case was erroneous, leading to their appeal to the Supreme Court.
- The Sup