Liang vs.

People of the Philippines

GR No. 125865
January 28, 2000

FACTS

Petitioner Jeffrey Liang is an economist working in the Philippine branch of the Asian Development
Bank. He was charged with grave oral defamation by Joyce Cabal, his co-employee. The petitioner was
arrested by virtue of a warrant issued by Metropolitan Trial Court of Mandaluyong City. The
Department of Foreign Affairs issued an “office of protocol” informing the judge of the Metropolitan
Trial Court that the petitioner is covered by immunity from legal processes under Section 45 of the
Agreement between the ADB and the Philippine Government. The judge then dismissed the two cases
against the petitioner; causing the prosecution to file a petition in the Pasig City-RTC. The latter then
ordered the Metropolitan Trial Court to enforce the warrant of arrest. The petitioner elevated the matter
to the Supreme Court.

ISSUES

W/n the petitioner is covered by immunity under the Agreement

HELD

The Supreme denied the petition of Lian6. It was not impressed with merit. Though the petitioner may
be covered by the immunity from legal processes under the Agreement; still, this immunity covers only
those acts performed in an official capacity. In this case, the Court said slandering a person could not be
possibly covered by the immunity agreement because Philippine laws do not allow the commission of
the crime in the name of official duty.