Government of the Philippine Island vs Monte de Piedad

35 Phil 728

Facts:
About $400,000 were paid into the treasury of the Philippine Islands by the inhabitants of
the Spanish Dominions for the relief of those damaged by the earthquake on June 3, 1863, in the
Philippines. Upon the petition of the governing body of the respondent, the Philippine
government directed its treasurer to turn over to the respondent the sum of $80,000 of the relief
fund in installments of $20,000 each. Petitioner now brings suit to recover said amount with
interest against respondents in behalf of the various petitions of the persons and heirs to whom
the relief was intended. Defendant contends that the amount was given as a donation and that the
court erred in stating that the Philippine Islands has subrogated the Spanish government in its
rights.

Issue:
Whether or not the government of the Philippines have authority to file a suit against the
respondent?

Held:
The legislature or government of the State, as parens patriae, has the right to enforce all
charities of public nature. The court further asserted that said amount was not a donation and that
respondent is liable for the debt regardless of the cession of the Philippine Islands to the United
States. It is said that there is a total abrogation of the former political relations of the inhabitants
of the ceded region, however, the circumstances present in the case are not political in nature.
The great body of municipal law which regulates private and domestic rights continue in force
until they are abrogated or changed by the new ruler.  As such, the government has the authority
to file a suit on behalf of its people by virtue of the principle of parens patriae.