Italy v Venezuela

Sambiaggo Case
Venezuela Arbitration of 1903,, p 666\

FACTS: Salvatore Sambiaggio, resident of the parish of San Joaquin, who claims
5,135.50 bolivars onaccount of requisition and forced loans exacted of him by
revolutionary troops. Commission has before it question as to whether the Venezuelan
Government is materially responsible to the claimant, Sambiaggio, and other Italians
established in Venezuela, on account of damages inflicted upon them by revolutionary
authorities or troops.
Revolutionist are not the agents of the Government and a natural responsibility
does not exist. Their acts are committed to destroy government and no one should be
held responsible for the acts of an enemy attempting his life. The revolutionists (in this
case) were beyond governmental control and the government cannot be held responsible
for injuries committed by those who have escaped its restraint. The word injury occurring
in the protocol imports legal injury; that is wrong inflicted on the sufferer and wrongdoing
by the party to be charged.

ISSUE:

RULING: