Political Law: 1987 Philippine Constitution of the private respondents.

There was
Topic: The Doctrine of State Immunity nothing personal or private about it.
 The Court concluded that, given the official
Dale Sanders and A.S. Moreau Jr. v Hon Regino T. character of the letters, the petitioners were,
Veridiano II, Anthony M. Rossi, and Ralph L. Wyers legally speaking, being sued as officers of
G.R. No. L-46930, June 10, 1988 the US government.
Ponente: Justice Cruz  As they have acted on behalf of that
government, and within the scope of their
authority, it is that government, and not the
Facts: petitioners personally, that is responsible for
their acts. Assuming that the trial can
 In 1975, the private respondents, Anthony M.
proceed, and it is proved that the claimants
Rossi, and Ralph L. Wyers, were advised
have a right to the payment of damages,
that their employment had been converted
such award will have to be satisfied not by
from permanent full-time to permanent part-
the petitioners in their personal capacities
time, effective October 18, 1975.
but by the United States government as their
 An alleged letter written, addressed to principal. This will require that government to
Moreau Jr., by Sanders, contained libelous perform an affirmative act to satisfy the
imputations that had exposed them to judgment, viz, the appropriation of the
ridicule and caused them mental anguish necessary amount to cover the damages
and that the prejudgment of the grievance awarded, thus making the action a suit
proceedings was an invasion of their against that government without its consent.
personal and proprietary rights.
 The private respondents filed in the Court of Therefore, the Court, speaking thru Justice Cruz,
First Instance of Olongapo City a claim for granted the petition.
damages against the petitioners, Dale
Sanders, and A.S. Moreau Jr.
 The respondents cleared that the petitioners
were being sued in their personal or private
capacity.
 A motion to dismiss was filed by the
petitioners arguing that the acts complained
of were performed by them in the discharge
of their official duties and that, consequently,
the court had no jurisdiction over them under
the doctrine of state immunity.
 CFI of Olongapo City ruled in favor of the
private respondents.
Hence, this Petition.
Issue:
Whether or not the petitioners were acting in
their official duties, hence, may validly invoke
the defense of “Doctrine of State Immunity”
Ruling/s:

 YES.
 Clearly, the petitioners performed the acts in
the discharge of their official duties. Sanders
wrote the letter as reply to his superior,
Moreau Jr, the other petitioner, for more
information regarding the case of private
respondents. Moreau Jr’s letter dealt with the
financial and budgetary problems of the
department and contained recommendations
for their solution, including the re-designation