GOVERNMENT vs EL MONTE

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 on 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 treasurer 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.
Because of the petition of the beneficiaries, the Attorney General in representation of the
Philippine Islands, file a 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 there was a change of sovereignty.
ISSUE: Whether or not the Philippine Islands has the capacity to file a suit against the Monte de
Piedad for the recovery of the said amount.
RULING:
When this country achieved its independence, the prerogatives of the crown devolved upon the
people of the States. And this power still remains with them except so fact as they have
delegated a portion of it to the Federal Government. The sovereign will is made known to us by
legislative enactment. The State as a sovereign, is the parens patriae.
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.