THE DOCTRINE OF STATE IMMUNITY contained libelous imputations that had exposed
them to ridicule and caused them mental
Section 3, Article XVI anguish and that the prejudgment of the
grievance proceedings was an invasion of their
1. Sanders vs Veridiano. GR No. L-46930. June
personal and proprietary rights.
10, 1988
The private respondents made it clear that the
Facts:
petitioners were being sued in their private or
Petitioner Sanders was, at the time the incident personal capacity. However, in a motion to
in question occurred, the special services dismiss filed under a special appearance, the
director of the U.S. Naval Station (NAVSTA) in petitioners argued that the acts complained of
Olongapo City. Petitioner Moreau was the were performed by them in the discharge of their
commanding officer of the Subic Naval Base, official duties and that, consequently, the court
which includes the said station. Private had no jurisdiction over them under the doctrine
respondent Rossi is an American citizen with of state immunity.
permanent residence in the Philippines, as so
The motion was denied.
was private respondent Wyer, who died two
years ago. They were both employed as Issue: W/N petitioners are immune from suit –
gameroom attendants in NAVSTA. YES
On October 3, 1975, the private respondents Held:
were advised that their employment had been
converted from permanent full-time to It is abundantly clear in the present case that the
permanent part-time, effective October 18, 1975. acts for which the petitioners are being called to
Thus, they instituted grievance proceedings account were performed by them in the
conformably to the pertinent rules and discharge of their official duties. Sanders, as
regulations of the U.S. Department of Defense. director of the special services department of
The result was a recommendation from the NAVSTA, undoubtedly had supervision over its
hearing officer who conducted the proceedings personnel, including the private respondents,
for the reinstatement of the private respondents and had a hand in their employment, work
to permanent full-time status plus backwages. assignments, discipline, dismissal and other
related matters. It is not disputed that the letter
In a letter addressed to petitioner Moreau, he had written was in fact a reply to a request
Sanders disagreed with the hearing officer's from his superior, the other petitioner, for more
report and asked for the rejection of the information regarding the case of the private
recommendation. The letter contained the respondents. Moreover, even in the absence of
statements that: a ) "Mr. Rossi tends to alienate such request, he still was within his rights in
most co-workers and supervisors;" b) "Messrs. reacting to the hearing officer's criticism—in
Rossi and Wyers have proven, according to their effect a direct attack against him—-that Special
immediate supervisors, to be difficult employees Services was practicing "an autocratic form of
to supervise;" and c) "even though the grievants supervision."
were under oath not to discuss the case with
anyone, (they) placed the records in public As for Moreau, what he is claimed to have done
places where others not involved in the case was write the Chief of Naval Personnel for
could hear." concurrence with the conversion of the private
respondents' type of employment even before
Private respondent filed with the CFI-Olongapo a the grievance proceedings had even
complaint for damages against the herein commenced. Disregarding for the nonce the
petitioners. The plaintiffs claimed that the letters question of its timeliness, this act is clearly
official in nature, performed by Moreau as the 6. Merritt vs Government of the Philippine
immediate superior of Sanders and directly Islands. GR No. 11154. March 21, 1916
answerable to Naval Personnel in matters
involving the special services department of Facts:
NAVSTA.
7. Amigable vs Cuenca. GR No. L-26400. Feb
Given the official character of the above- 29, 1972
described letters, we have to conclude that the
Facts:
petitioners were, legally speaking, being sued as
officers of the United States government. As 8. Republic vs Sandiganbayan. GR No. 90478.
they have acted on behalf of that government, Nov 21, 1991
and within the scope of their authority, it is that
government, and not the petitioners personally, Facts:
that is responsible for their acts.
9. China National Machinery & Equipment vs
There should be no question by now that such Santamaria. GR No. 185572. Feb 7, 2012
complaint cannot prosper unless the government
sought to be held ultimately liable has given its Facts:
consent to' be sued. The practical justification for
10. Republic vs Feliciano. GR No. 70853. March
the doctrine, as Holmes put it, is that "there can
12, 1987
be no legal right against the authority which
makes the law on which the right depends. Facts:
A final consideration is that since the questioned 11. US vs Ruiz. GR No. L-35645. May 22, 1985
acts were done in the Olongapo Naval Base by
the petitioners in the performance of their official Facts:
duties and the private respondents are
themselves American citizens, it would seem 12. The Holy See vs Rosario. GR No. 101949.
only proper for the courts of this country to Dec 1, 1994
refrain from taking cognizance of this matter and
Facts:
to treat it as coming under the internal
administration of the said base. 13. Republic vs Villasor. GR No. L-30671. Nov
28, 1973
2. Republic vs Sandoval. GR No. 84607. March
19, 1993 Facts:
Facts: 14. Department of Agriculture vs NLRC. GR No.
104269. Nov 11, 1993
3. Festejo vs Fernando. GR No. L-5156. March
11, 1954 Facts:
Facts: 15. PNB vs Pabalan. GR No. L-33112. June 15,
1978
4. US vs Guinto. GR No. 76607. Feb 26, 1990
Facts:
Facts:
16. Rayo vs CFI-Bulacan. GR No. L-55273-83.
5. Veterans Manpower & Protective Services vs
Dec 19, 1981
CA. GR No. 91359. Sept 25, 1992
Facts:
Facts:
17. Bureau of Printing vs Bureau of Printing
Employees Assoc. GR No. L-15751
Facts:
18.
19.
20.
21.
22.
23.
24.