Syquia v.

Almeda, Lopez
G.R. No. L-1648             August 17, 1949
Facts:
Petitioners Pedro, Gonzalo and Leopoldo Syquia are joint owners of properties in
Manila, namely, the North Syquia Apartments, South Syquia Apartments and Michel
Apartments. In 1945, they executed contracts for lease of the apartments to USA, with the term
being until the war has ended and six months after, or unless terminated sooner by USA, as the
buildings were used for billeting and quartering officers of the US armed forces stationed in the
Manila Area.
George Moore, a Commanding General of the US Army, and Erland Tillman, Chief of the
Real Estate Division to the US Army in Manila who was under the command of Moore, was said
to be in control of the apartment buildings and had authority in the name of USA to assign
officers of the army to the buildings or order them to vacate the same. When Japan
surrendered on September 2, 1945, the lease would be terminated six months after. The
petitioners approached the predecessors of Moore and Tillman and requested the buildings to
be returned to them, as per contract agreement.
However, they were advised that the US Army wanted to continue their occupancy of
the buildings, and refused to execute new leases but advised that they will vacate the premises
before February 1, 1947, not the original terms of the contract agreement. Petitioner-plaintiffs
sued before the Municipal Court of Manila with the demand to get the properties as their
agreement supposedly expired, and furthermore asked for increased rentals until the premises
were vacated. Respondent-defendants were part of the armed forces of the US moved to
dismiss the suit for lack of jurisdiction on the part of the court. The MC of Manila granted the
motion to dismiss the suit, sustained by the CFI of Manila, hence the petition for certiorari.
Issue:
Whether the Philippine Courts have a lack of jurisdiction, considering, under the
doctrine of Sovereign Immunity, that USA has not given their consent to be a respondent.
Ruling:
No. Considering the circumstances, the real defendant party is the United States of
America, as it was the U.S. Army who were occupying the buildings, with the rent being paid for
by their government. USA has not given their consent to be sued in this case, and any action
against them without the consent would constitue a lack of jurisdiction.
Case dismissed, without pronouncement as to costs.