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Holy See vs.

Rosario
Under the Constitution, generally accepted principles of International Law are
adopted by our Courts and shall form part of the laws of the land.
Under the 1961 Vienna Convention on Diplomatic Relations, diplomatic
envoy shall be granted immunity from civil and administrative jurisdiction of
the receiving state over any real action relating to private immovable
property. Embassy of Holy See was also accredited by the DFA as a
diplomatic missionary.
In this case, Holy See may properly invoke sovereign immunity for its nonsuability since the act of selling the subject lot is non-propriety in nature. The
lot was acquired through a donation from the Archdiocese of Manila, not for a
commercial purpose, but for the purpose of constructing the official place of
residence of the Papal Nuncio thereof. The transfer of the property and its
subsequent disposal are likewise clothed with a governmental (nonproprietal) character as petitioner sold the lot not for profit or gain rather
because it merely cannot evict the squatters living in said property.

Mendoza vs. DPWH


DPWH is an unincorporated government agency without any separate
juridical personality of its own and it enjoys immunity from suit because it is
invested with an inherent power of sovereignty.
The contracts that the DPWH entered into with Mendoza for the construction
of Packages VI and IX of the HADP were done in the exercise of its
governmental functions. Hence, petitioners cannot claim that there was an
implied waiver by the DPWH simply by entering into a contract.