Parens Patriae
The Government of
Philippine Islands vs El Monte de Piedad Y Caja de Ahorras de Manila
G.R. No. L-9959
December 13, 1916
Facts:
On June 3, 1863, an Earthquake
took place in the Philippine Islands, which was then under the Spanish Crown, that devastated lot of civilians.
Therefore n Oct. 6 of that year, a central relief board was appointed, by
authority of the King of Spain, to distribute the money voluntarily contributed
by donors. After a thorough investigation and consideration, the relief board
allotted $365703.50 to the various sufferers name in its resolution.
These were later distributed in
accordance with the above mentioned allotments, the sum of $30,299.65, leaving
a balance of $365.403.85 for distribution. Upon the petition of the governing
body of the Monte de Piedad, dated February 1, 1833, the Philippine Government,
by order dated the first month, directed its treasured to turn over Monte de
Piedad the sum of $80,000 of relief fund in its installment of 20,000 each.
These amounts received on the following dates: February 15, March 12, April 14,
and June 2, 1883, and are still in the possession of Monte de Piedad.
The Attorney General in
representation of the Philippine Islands, a file of claim for the $80000
together with interest, for the benefit of those persons or their heirs
appearing in the list of names published in the Official Gazette instituted on
May, 3, 1912 by the Government of the Philippine Islands, represented by the
Insular Treasurer, and after due trial in the lower court, judgment was entered
in honor of the plaintiff currency, together with legal interest from February
28, 1912, and cost of cause. The Monte de Piedad then contended that the
present Philippine Government cannot file suit on the ground that the obligation
of the former was wiped out when their was a change of sovereignty.
Issue:
Whether or not the government of
the Philippine Islands has capacity to file a suit against the Monte de Piedad
for the recovery of the said amount.
Ruling:
Under the Principle of Parens
Patriae, the Philippine Government being the guardian of the “rights of the
people” can represent the legitimate claimants of the beneficiary and therefore
has the capacity to file a suit against the appellant. The Philippine Government
is not merely a nominal party that’s why it can bring and prosecute this action
by exercising its sovereign powers. The supreme court then held the right of
the government to file the case.