Title
The Holy See vs. Rosario, Jr.
Case
G.R. No. 101949
Decision Date
Dec 1, 1994
The Holy See invoked sovereign immunity in a land sale dispute with Starbright, claiming its actions were diplomatic, not commercial. The Supreme Court upheld immunity, dismissing the case.

Case Summary (G.R. No. 101949)

Trial Court Proceedings

Starbright filed for annulment of the Holy See’s sale to Tropicana, specific performance of its own contract, and damages (lost profits ≥₱30 million). The Holy See moved to dismiss for lack of jurisdiction based on sovereign immunity; Msgr. Cirilos moved as an improper party. On June 20, 1991 and September 19, 1991, the RTC denied both motions, finding that by entering into the sale contract the Holy See had waived immunity.

Intervention by the Department of Foreign Affairs

The Department of Foreign Affairs (DFA) sought to intervene to affirm the Holy See’s diplomatic immunity, adopting its arguments. The Supreme Court allowed the DFA to submit a memorandum and formal certification that the Holy See’s mission enjoys immunity from local jurisdiction.

Reviewability of the RTC Orders

While orders denying motions to dismiss are generally unappealable, exceptions arise when the trial court clearly lacks jurisdiction. The Court held that certiorari under Rule 65 is proper if the complaint must be dismissed as a matter of law and proceeding to trial would waste resources.

Status of the Holy See as a Sovereign State

Under the 1987 Constitution’s adoption of International Law, the Holy See is recognized as a foreign sovereign. The Lateran Treaty (1929) and universal diplomatic practice affirm its international personality. In Philippine practice, the DFA’s executive determination of diplomatic immunity is conclusive.

Doctrine of Sovereign Immunity

Two theories prevail:

  • Absolute: no suit without consent.
  • Restrictive: immunity for public (jure imperii) acts but not private or commercial (jure gestionis) acts.

Philippine jurisprudence adopts a functional approach: if a transaction is in the sovereign’s proprietary capacity and undertaken for profit, immunity is impliedly waived; if in its governmental capacity or for noncommercial purposes, immunity applies.

Application to the Holy See’s Transactions

The Holy See acquired Lot 5-A not for profit but to house its diplomatic mission, a privilege recognized under the Vienna Convention on Diplomatic Relations. Its later sale was motivated by the inability to use the property, not by commercial gain. Starbright’s complaint admitted the presence of squatters and the Holy See’s noncommercial purpose.

Executive Determination and Jurisdictional Impact

The DFA’s certification that the Holy See’s mission i


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