GR L 11944; (August, 1960) (Digest)
G.R. No. L-11944; August 31, 1960
PHILIPPINE RACING CLUB, ET AL., petitioners, vs. ARSENIO BONIFACIO, ET AL., respondents.
FACTS
During a horse race at the Sta. Ana Hippodrome on July 23, 1950, there was a faulty start. The official starter signaled to the stewards (who were also acting as judges) that the race should be cancelled. When his signal was ignored, he personally informed them, but one steward told him to “shut up,” and the race was allowed to proceed. After the winners and dividends were announced, the betting public protested. The members of the Commission on Races, upon learning of the commotion, conducted an on-the-spot investigation. Convinced the start was faulty, they decided to cancel the race and announced this decision. However, holders of winning tickets had already cashed them. Consequently, the Philippine Racing Club paid the winning dividends and also refunded P5,032 to holders of losing tickets. The Club sued the Commission members for actual and moral damages, alleging they acted without or in excess of authority. The trial court ruled in favor of the Club. The Court of Appeals reversed this decision, leading to this petition for review.
ISSUE
Whether the members of the Commission on Races can be held civilly liable for damages for ordering the cancellation of the horse race after an on-the-spot investigation.
RULING
No. The decision of the Court of Appeals is affirmed. The Commission on Races acted within the scope of its official authority and is not liable for damages.
The governing law is Republic Act No. 309 , which created the Commission on Races and charged it with the supervision and regulation of all horse races in the Philippines. The pertinent rules (Articles 1, 28, and 29) provide: the Commission has supervisory power; stewards have the power to annul a race before the horses reach the finish if, in their opinion, there is a bad start; and judges decide the race with finality. The Court found that the stewards’ failure to cancel the obviously faulty race, despite the official starter’s recommendation, was an error in the exercise of their discretion. The Commission, in the exercise of its overarching supervisory powers under the law, had the authority to investigate and act upon this matter. In cancelling the race, the Commission members were performing their official duty. Citing American Jurisprudence, public officers are not personally liable for damages resulting from the exercise of their discretionary authority, provided the acts are within the scope of their authority and are done without wilfulness, malice, or corruption. The respondents acted in good faith in the line of duty; therefore, they incur no civil liability.