GR L 1648; (August, 1949) (Digest)
G.R. No. L-1648; August 17, 1949
PEDRO SYQUIA, GONZALO SYQUIA, and LEOPOLDO SYQUIA, petitioners, vs. NATIVIDAD ALMEDA LOPEZ, Judge of Municipal Court of Manila, CONRADO V. SANCHEZ, Judge of Court of First Instance of Manila, GEORGE F. MOORE, ET AL., respondents.
FACTS
Petitioners, the Syquias, are co-owners of three apartment buildings in Manila leased to the United States of America in 1945. The lease was “for the duration of the war and six months thereafter, unless sooner terminated by the United States of America.” The buildings were used to billet U.S. Army officers. Petitioners contended the lease terminated six months after Japan’s surrender (September 2, 1945). In 1946, they requested cancellation or renegotiation for higher rentals. U.S. Army representatives refused but indicated an intent to vacate by February 1, 1947. When the buildings were not vacated by that date, petitioners filed an unlawful detainer action in the Manila Municipal Court against the commanding officers (Moore and Tillman) and the individual occupying officers, seeking ejectment and increased rentals. The municipal court dismissed the case, ruling the real party in interest was the U.S. Government, which could not be sued without its consent. The Court of First Instance affirmed the dismissal.
ISSUE
Whether the municipal court had jurisdiction over the unlawful detainer case against the U.S. Army officers, or whether the suit was effectively against the United States Government, which is immune from suit without its consent.
RULING
The Supreme Court affirmed the dismissal. The suit was deemed to be against the United States Government. The individual defendants, being officers of the U.S. Army, occupied the apartments in their official capacity as agents of the U.S. Government. The government was the lessee and the real party in interest. A judgment for ejectment and payment of rentals would require the U.S. Government to perform its contractual obligations, effectively suing the government without its consent. The principle of state immunity from suit bars such an action. The proper recourse for petitioners is through diplomatic channels by representation of the Philippine Government to the U.S. Government.
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