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GP vs Monte de Piedad

Doctrine of Parents Patria


GP VS MONTE DE PIEDAD
G.R. No. L-9959 December 13, 1916
THE GOVERNMENT OF THE PHILIPPINE ISLANDS, represented by the Treasurer of the Philippine Islands, plaintiff-
appellee,
vs.
EL MONTE DE PIEDAD Y CAJA DE AHORRAS DE MANILA, defendant-appellant.
Facts:
A devastating earthquake took place in the Philippines sometimes in 1863. Contributions amounting to
$400,000 were collected during the Spanish regime for the relief of the victims of an earthquake. Out of the aid,
$80,000.00 was left untouched. The Monte de Piedad, a charitable institution, in need for more working capital,
petitioned the Governor-General for the transfer of $80,000 as a loan.
In June 1893, the Department of Finance called upon the Monte de Piedad to return the $80,000. The
respondent bank declined to comply with this order upon the ground that only the Governor-General of the
Philippine Islands and not the Department of Finance had the right to order the reimbursement.
On account of various petitions of the persons, the Philippine Islands, through the Attorney-General, bring suit
against the Monte de Piedad for a recover of the $80,000, together with interest, for the benefit of those
persons or their heirs. After due trial, judgment was entered in favor of the plaintiff for the sum of $80,000 gold
or its equivalent in Philippine currency, together with legal interest from February 28, 1912, and the costs of the
cause.
The defendant appealed. One of the assignment of errors made by the defendant was to question the
competence of the plaintiff (government) to bring the action, contending that the suit could be instituted only
by the intended beneficiaries themselves or by their heirs.
Issues:
Whether or not the Philippine government is competent to file a complaint against the respondent bank for the
reimbursement of the money of the intended beneficiaries?
Discussions:
In accordance with the doctrine of Parents Patriae. The government being the protector of the rights of the
people has the inherent supreme power to enforce such laws that will promote the public interest. No other
party has been entrusted with such right hence as “parents” of the people the government has the right to take
back the money intended for the people.
Rulings:
Yes. The Supreme Court upheld the right of the Government to file the case as parents patriae in representation
of the legitimate claimants. The legislature or government of the State, as parents patriae, has the right to
enforce all charities of public nature, by virtue of its general superintending authority over the public interests,
where no other person is entrusted with it.
This prerogative of parents patriae is inherent in the supreme power of every State, whether that power is
lodged in a royal person or in the legislature. It is most beneficent functions, and often necessary to be exercised
in the interest of humanity, and for the prevention of injury to those who cannot protect themselves. The
beneficiaries of charities, who are often in capable of vindicating their rights, and justly look for protection to
the sovereign authority, acting as parents patriae. They show that these beneficent functions have not ceased to
exist under the change of government from a monarchy to a republic; but that it now resides in the legislative
department, ready to be called into exercise whenever required for the purposes of justice and right and is a
clearly capable of being exercised in cases of charities as in any other cases whatever.