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4. Scope of Consent a) Under Act No.

3083;

REPUBLIC ACT No. 3083

An Act to Regulate the Filing, Processing and Settlement of Damage


Claims Resulting from Nuclear Incidents, to Appropriate Funds Therefor,
and to Hold Harmless, Indemnify, and Defend the Designer, Manufacturer,
Contractor and/or Supplier that Shall Undertake to Design, Manufacture,
Furnish and/or Supply the Reactor Facility and Equipment for the
Philippine Nuclear Research Reactor Project and Other Similar Projects
from Liability Arising from Nuclear Incidents, and for Other Purposes

Be it enacted by the Senate and House of Representatives of the Philippine


Congress Assembled:

Section 1. In order to protect the inhabitants of the Philippines and to promote


the peaceful uses of atomic energy, in the interest of the general welfare of the
Philippines, the Government of the Republic of the Philippines shall indemnify
and hold harmless and defend at its expense the designer, manufacturer,
contractor and/or supplier that shall undertake to design, manufacture for, or
otherwise furnish equipment or services to the Philippine Government, its
instrumentality or agency, for the reactor facility or other equipment for the
Philippine Nuclear Research Reactor Project, from any and all liability for
personal injury or property damage arising out of or resulting from a nuclear
incident, and the National Science Development Board is hereby empowered to
provide by contract with the designer, manufacturer, contractor and/or supplier
of nuclear equipment, that such designer, manufacturer, contractor and/or
supplier shall be indemnified, held harmless and defended at the expense of the
Philippine Government from any and all liability arising out of or resulting from
a nuclear incident: Provided, However, That the Government shall retain
whatever rights it may otherwise have under existing laws against said
manufacturer, contractor, or supplier if the nuclear incident is the proximate
result of willful misconduct, or bad faith, on the part of any corporate officer,
director, or responsible officers of the designer, manufacturer, contractor and/or
supplier, as the case may be: Provided, further, That the total liability of the
designer, manufacturer, contractor and/or supplier shall not exceed the total
value of the contract price: Provided, finally, That the total liability of said
designer, manufacturer, contractor and/or supplier shall be over and above the
liabilities, obligations and warranties assumed by it on the services, equipment,
and materials furnished under its contract with the National Science
Development Board for the furnishing of the equipment and services for the
reactor facility or other equipment of the Philippine Nuclear Research Reactor
Project.
Responsible officers as used in this section shall be determined in the indemnity
agreement to be executed between the National Science Development Board
and said designer, manufacturer, contractor and/or supplier.1avvphi1

Section 2. For the purposes of this Act:

(a) The term "Nuclear Research Reactor Project" is meant the reactor
project established or to be established under the Agreement for
Cooperation between the Government of the Republic of the Philippines
and the Government of the United States of America signed on July 27,
1955, including its amendments.

(b) The term "liability" means any liability for personal injury or property
damage arising out of or resulting from a nuclear incident.

(c) The term "personal injury" means bodily injury, sickness, or disease,
including death resulting therefrom.

(d) The term "property damage" or "damage to property" means physical


injury to or destruction or radioactive contamination of property, or loss
of use of property so injured, destroyed or contaminated.

(e) The term "nuclear incident" means any occurrence causing personal
injury or property damage arising out of or resulting from the radioactive,
toxic, explosive, or other hazardous properties of radioactive material.

Section 3. In order to carry out the purpose of this Act and to adjudicate claims
for compensation for personal injury or property damage arising out of or
resulting from a nuclear incident, there is hereby created a Nuclear Indemnity
Board to be composed of the Vice-Chairman of the National Science
Development Board as Chairman, the Commissioner of the Philippine Atomic
Energy Commission and one other member to be appointed by the President of
the Philippines, with the consent of the Commission on Appointments, who
must be a diplomate in radiology or medical radio-therapy with at least five
years of clinical practice, as members.1awp++i1 The Vice-Chairman of the
National Science Development Board and the Commissioner of the Philippine
Atomic Energy Commission shall serve ex officio without extra compensation
and the third member shall receive a per diem of fifty pesos for each meeting
actually attended: Provided, That the monthly total of such per diem shall not
exceed two hundred pesos.1awp++i1 The operating expenses of the Nuclear
Indemnity Board shall be borne out of the regular appropriation of the National
Science Development Board.
No action, suit or proceeding for compensation for personal injury or property
damage arising out of or resulting from a nuclear incident may be instituted
against the designer, manufacturer, contractor and/or supplier of nuclear
equipment, and all such claims for compensation shall be filed with the Nuclear
Indemnity Board which is hereby exclusively empowered to settle the above-
mentioned claims on a fair and reasonable basis taking into due account the
purposes of this Act: Provided, However, That any provision of law to the
contrary notwithstanding, any such claim shall be barred unless brought within
ten years from the date of the event causing injury or damage and within two
years from time to time the injury or damage, or a subsequent aggravation
thereof, came to the knowledge of, or could have been ascertained by the
exercise of ordinary care by the aggrieved party: Provided, further, That the
proper courts of the Republic of the Philippines shall have exclusive jurisdiction
in the case of a nuclear incident occurring in the course of carriage of fuel
elements or other radioactive materials capable of causing a nuclear incident
belonging to or in the charge of the Philippine Government, or any of its
agencies or instrumentalities, where such nuclear incident occurs outside
Philippine territory: And Provided, finally, That the aggregate liability of the
Philippine Government under this Act shall not exceed the amount of five
million pesos which is hereby appropriated out of any funds in the National
Treasury not otherwise appropriated.

Section 4. For the purpose of carrying out its functions under this Act the
Nuclear Indemnity Board shall have the following powers:

(a) To promulgate such rules and regulations as may be necessary to carry


out the purposes of this Act including rules or procedure governing the
filing, processing and settlement of claims: Provided, However, That the
concurrence of at least two members shall be required in order for the
Board to make an award, order or decision: Provided, further, That in the
hearing, investigation and determination of any question or controversy,
and in exercising any duties and powers under this Act, the Nuclear
Indemnity Board shall act according to justice and equity and substantial
merits of the case, and shall use every and all reasonable means to
ascertain the facts in each case speedily and objectively and without
regard to technicalities of law or procedure;

(b) To issue subpoena and subpoena duces tecum;

(c) To administer oaths;

(d) To grant reasonable compensation in an amount not more than


twenty-five pesos for each day of attendance, but in no case to exceed
more than one hundred pesos a month, to an expert witness or resource
person who is not a government official or employee, whose services may
be availed of by the Nuclear Indemnity Board as provided herein; and

(e) Such other powers as may be necessary to carry out the purposes of
this Act.

Section 5. Upon a showing that the government’s liability in any one incident
will probably exceed the limit of liability imposed by the preceding section, the
Board may, in its sound discretion, for the purpose of ensuring the equitable and
just distribution of damages, either issue orders apportioning the payments and
permitting partial payments to be made to claimants or issue an order setting
aside a part of the funds available for possible latent injuries not discovered
until a later time, or both.

Section 6. When a nuclear incident occurs, the Board shall investigate or cause
to be investigated the cause or extent of the damage and may for that purpose
compel all persons exposed to radiation to report to the Board for examination
not later than three months from the date of the order requiring their appearance.
In determining the amount of damages the Board may, in its sound discretion,
take into account the inexcusable violation of the foregoing obligation to report
to the Board for examination.

Section 7. The Nuclear Indemnity Board is hereby authorized to call upon the
National Science Development Board, the Philippine Atomic Energy
Commission and other government agencies and instrumentalities for assistance
and cooperation in the discharge of its powers, duties and functions under this
Act.

Section 8. Any aggrieved claimant may appeal from any final order, award or
decision of the Board to the Supreme Court in accordance with the provisions of
Rule forty-five of the Rules of Court. Findings of fact by the Board shall be
conclusive in the absence of fraud, collusion or evident mistake.

Section 9. This Act shall take effect upon its approval.


Scope of Consent Under Act No. 3083 COMM. V. SAN DIEGO 2/18/70

Background Facts:

1. In 1940, the Government of the Philippines initiated an eminent domain


proceeding to expropriate a parcel of land owned by N. T. Hashim to
construct a public road, now known as Epifanio de los Santos Avenue.
2. In 1940, the government took possession of the property after depositing
a sum of P23,413.64 with the City Treasurer, representing the provisional
value of all lots needed for the road, including Hashim's property.
3. The records of the expropriation case were lost during World War II, and
no steps were taken to reconstitute the proceedings afterward.
4. In 1958, the Estate of N.T. Hashim filed a money claim for P522,620.00
with the Quezon City Engineer's Office, alleging this as the fair market
value of the property, now a public highway.
5. In 1963, the estate filed a complaint to recover the fair market price of the
property, amended to include additional defendants, such as the Bureau of
Public Highways.
6. The parties eventually reached a compromise agreement, and the court
approved it, ordering the Bureau of Public Highways to pay P209,076.00
to the estate.
7. The estate filed a motion for execution in 1968 when the judgment was
not satisfied.
8. Respondent Judge issued a writ of execution and notice of garnishment
against the Bureau of Public Highways' funds deposited in the Philippine
National Bank.
9. Respondent bank, through its Chief Documentation Staff, replied to the
notice of garnishment and released the garnished amount to the estate.
10.The Bureau of Public Highways demanded the return of the garnished
funds, and respondent bank complied.
11.The Bureau of Public Highways then filed a special civil action for
certiorari and prohibition, seeking the nullification of the court orders
allowing the garnishment.

Court's Ruling and Reasoning:

1. Government funds are not subject to execution or garnishment: The court


emphasized the long-standing principle that government funds are not
subject to execution or garnishment. This principle is based on public
policy to ensure that government functions are not disrupted, and public
funds are used for their intended purposes as authorized by legislative
appropriation.
2. Government's consent to be sued does not extend to execution: While the
government may consent to be sued in certain cases, such consent only
extends to the point of establishing liability. Once a judgment is rendered,
the government must rely on legislative appropriation to satisfy the
judgment, and execution or garnishment of government funds is not
allowed.
3. Compromise agreement and ratified judgment: The court noted that the
compromise agreement was reached with the approval of the proper
government officials, and the estate had confirmed and ratified it.
Therefore, the compromise agreement and the judgment based on it were
valid.
4. Appointment of "special sheriff": The court found that the appointment of
a "special sheriff" to serve the writ of execution was unauthorized by law.
The duty of executing processes, including writs of execution, falls upon
the sheriff or their deputies, and special sheriffs can only be appointed in
specific circumstances defined by law.
5. Civil liability of respondents: The court clarified that respondents special
sheriff and deputy clerk were not personally liable since they acted in
accordance with court orders. The immunity from civil responsibility of
respondent Judge extended to them as well.
6. Reimbursement of funds: The court ordered the Estate of N. T. Hashim
and Tomas N. Hashim to jointly and severally reimburse the Philippine
National Bank in the amount of P209,076.00 with legal interest.
Additionally, it ordered the Estate of N. T. Hashim, Philippine National
Bank, and Benjamin Coruña to jointly pay treble costs.
7. Administrative action against bank officials: The court recommended that
the bank's Board of Directors and management take appropriate
administrative action against bank officials for their improper handling of
the garnishment, including failing to require reimbursement from the
estate.

In summary, the court's ruling emphasized the inviolability of government funds


against execution or garnishment, recognized the validity of the compromise
agreement and judgment, and nullified the appointment of a "special sheriff." It
also ordered reimbursement of funds to the Bureau of Public Highways and
suggested administrative action against bank officials for their role in the
improper garnishment of government funds.
b) Under a Charter- PNB V. CIR 1/32/78
The case originated from labor disputes between the United Homesite Employees and Laborers Association (UHELA)
and the People's Homesite and Housing Corporation (PHHC). UHELA, represented by Gabriel V. Manansala as its
counsel, was the prevailing party in these disputes.

Facts and Proceedings: After the labor disputes were resolved in favor of
UHELA, the Court of Industrial Relations (CIR) issued a decision that became
final and executory. This decision included an award of attorney's fees in favor
of Gabriel V. Manansala as counsel for UHELA. To satisfy the judgment and
the attorney's fees, the CIR issued a writ of execution. Gilbert P. Lorenzo was
appointed as an authorized deputy sheriff by the CIR to serve the notice of
garnishment on the Philippine National Bank (PNB). PNB, which held funds
deposited by the PHHC in its Quezon City branch, received the notice of
garnishment and filed a motion to quash it. PNB raised two main objections:
a. Appointment of Gilbert P. Lorenzo: PNB argued that Lorenzo's appointment
as an authorized deputy sheriff was contrary to law. PNB contended that the
Sheriff of Quezon City, not the Clerk of the CIR, was its Ex-Officio Sheriff and
had the authority to serve notices of garnishment. PNB claimed that the service
of the notice by the Clerk of the CIR was not in order.
b. "Public in Character" Funds: PNB also contended that the funds deposited by
the PHHC in its branch could be of a "public in character." While not
categorically asserting that the funds were public, PNB argued that the
possibility of their being public in character raised doubts about their
susceptibility to garnishment.
The CIR denied PNB's motion to quash the notice of garnishment, finding no
merit in PNB's arguments. The CIR pointed out that Republic Act No. 4201,
enacted on June 19, 1965, had already repealed Commonwealth Act No. 103
and granted the Clerk of the CIR the authority to serve as the Ex-Officio Sheriff.
The Clerk of the CIR's area of authority was coterminous with that of the Court
itself, which was national in nature. The CIR also noted that the appeal to the
Supreme Court by individual employees of PHHC, questioning the award of
attorney's fees to Atty. Gabriel V. Manansala, had been dismissed and had
become final and executory on August 9, 1970. Therefore, there was no reason
to withhold action on the case.
The CIR denied in a resolution dated September 22, 1970 and dissatisfied with
the CIR's decision and resolution, PNB filed a petition for certiorari with the
higher court, seeking to nullify the orders of the CIR and have the notice of
garnishment quashed.
Issues: Whether the appointment of Gilbert P. Lorenzo as an authorized deputy
sheriff was contrary to law.
Whether the funds deposited by PHHC in PNB could be considered "public in
character" and thus exempt from garnishment.
Court's Ruling and Reasoning: Appointment of Gilbert P. Lorenzo: The Court
ruled that Lorenzo's appointment as an authorized deputy sheriff to serve the
notice of garnishment was not contrary to law. It cited Republic Act No. 4201,
which had repealed Commonwealth Act No. 103 and granted the Clerk of the
CIR the authority to serve as the Ex-Officio Sheriff. The Clerk of the CIR had
the authority to issue writs of execution and notices of garnishment nationwide.
Therefore, Lorenzo's appointment was lawful, and PNB's objection on this
ground was not valid. "Public in Character" Funds: PNB argued that the funds
might be "public in character," and as such, they should be exempt from
garnishment. However, the Court cited the precedent set in the National
Shipyard and Steel Corporation v. Court of Industrial Relations case, which held
that even if a government-owned or controlled corporation had a government
connection, it still had a separate juridical personality and could be subjected to
garnishment. The Court emphasized that such entities could sue and be sued,
similar to private corporations, and their funds were not automatically immune
from garnishment. Additionally, the Court cited the Manila Hotel Employees
Association v. Manila Hotel Company case, which explained that when the
government engages in commercial business through a corporation, it abandons
its sovereign capacity and is treated like any other corporation. Therefore, the
"public in character" argument did not hold, and the funds of PHHC deposited
in PNB were subject to garnishment.
In conclusion, the Court found that the denial of PNB's motion to quash the
notice of garnishment was not a grave abuse of discretion. It held that the
appointment of Gilbert P. Lorenzo was valid, and the funds deposited by PHHC
in PNB were not exempt from garnishment due to their "public in character" but
rather were subject to execution in favor of the prevailing party. Consequently,
the petition for certiorari was dismissed, and PNB was ordered to comply with
the notice of garnishment. This case underscores the principle that government-
owned or controlled corporations, even if they have a government connection,
possess a separate juridical personality and can be sued and subjected to
garnishment like private corporations.
c) Execution- DFA V. NLRC 9/18/96;

Facts:

1. Jose C. Magnayi initiated NLRC-NCR Case No. 00-01-0690-93 against


the Asian Development Bank (ADB) on January 27, 1993, alleging illegal
dismissal and violation of the "labor-only" contracting law.
2. Two summonses were served, one directly to ADB and the other through
the Department of Foreign Affairs (DFA), both with a copy of the
complaint.
3. ADB and DFA notified the Labor Arbiter that ADB, its President, and
Office were covered by diplomatic immunity from legal process except
for certain specified cases as per the ADB's Charter and Headquarters
Agreement.
4. The Labor Arbiter proceeded with the case, assuming that ADB had
waived its diplomatic immunity from suit. He rendered a decision on
August 31, 1993, declaring Magnayi as a regular employee of ADB and
ordering reinstatement, back wages, benefits, and attorney's fees.
5. ADB did not appeal the decision but instead referred the matter to the
National Labor Relations Commission (NLRC) through DFA, seeking the
vacation of the judgment.
6. The NLRC Chairman responded that the request was based on an
erroneous provision of the Labor Code and suggested that the DFA file a
complaint with the Office of the Ombudsman if it believed there was
misconduct.
7. Unsatisfied with this response, the DFA filed a petition for certiorari to
the Supreme Court, challenging the Labor Arbiter's decision.

Main Issues:

1. Whether ADB was entitled to diplomatic immunity from legal process.


2. Whether the DFA had the legal standing to file the petition for certiorari.
3. Whether certiorari was the appropriate remedy.

Court's Ruling with Reasoning:

1. The Supreme Court ruled in favor of ADB's entitlement to diplomatic


immunity from legal process. The Charter and Headquarters Agreement
of ADB provided clear provisions granting the bank and its officials
immunity from legal process except in specific cases related to borrowing
money, guaranteeing obligations, or buying and selling securities. These
provisions were considered treaty covenants voluntarily assumed by the
Philippine government and must be respected.
The Court cited the principle of diplomatic immunity in international law,
which is essentially a political question, and courts should defer to the
executive branch's determination of diplomatic immunity. In this case, the
DFA, by filing the petition, affirmed the government's recognition of
ADB's immunity.
The Court also emphasized that ADB, as an international organization, is
independent of municipal law, and subjecting it to local courts would
interfere with its operations and decisions.
2. The Court affirmed that the DFA had legal standing to file the petition.
The DFA has a role in determining persons and institutions covered by
diplomatic immunities, and challenging such immunities in court was
necessary to maintain the credibility of the Philippine government in
international relations.
3. Certiorari was deemed the appropriate remedy in this case because the
Labor Arbiter's decision was considered a patent nullity. The decision
was rendered without jurisdiction because ADB's diplomatic immunity
should have been recognized, and the Labor Arbiter had no authority to
proceed with the case. In such circumstances, certiorari was a valid
recourse to rectify the error.

Therefore, the Court granted the petition for certiorari, vacated the Labor
Arbiter's decision, and made the temporary restraining order permanent. The
decision dated August 31, 1993, was declared null and void.
CALOOCAN V. ALLARDE, 8/10/03;
 The case involves a dispute between the City of Caloocan, Norma M.
Abracia, and Delfina Hernandez Santiago.
 In 1972, the City Mayor of Caloocan abolished several positions in the
city government, including that of Assistant City Administrator held
by Delfina Hernandez Santiago.
 Santiago and other affected employees challenged the abolition in
court, leading to legal proceedings.
 In 1973, the court declared the abolition illegal and ordered the
reinstatement of the employees with back salaries.
 The City Government of Caloocan appealed the decision multiple
times, reaching the Supreme Court.
 In 1985, the Supreme Court ruled against the City Government,
upholding the reinstatement and back salaries.
 Partial payment of back salaries was made in 1986, but a substantial
balance remained.
 Legal disputes continued, and in 1991, a writ of execution was issued
to enforce Santiago's claim.
 The City Government opposed the execution, arguing that Santiago
was not entitled to backwages for certain years.
 Santiago sought clarification from the Civil Service Commission
(CSC) regarding her entitlement to back salaries.
 The CSC initially ruled against Santiago, but the Supreme Court
eventually ruled in her favor in 1995.
 In 1992, the City Council of Caloocan approved an ordinance to
allocate funds for Santiago's back salaries, including interest.
 The City Mayor, however, refused to sign the check for Santiago's
payment despite approving the ordinance.
 In response to the refusal, a court ordered the garnishment of the City's
funds deposited in the Philippine National Bank (PNB).
 PNB complied with the court order and released the funds to the
Sheriff, settling Santiago's claim after 21 years.
 During the proceedings, there were allegations of irregularities in the
auction sale of a City Government vehicle, but these were not
substantiated.
 Norma M. Abracia, a city official, was cited for contempt for not
surrendering Division of City Schools vehicles, but she later agreed to
surrender them under certain conditions.
Main Issues:
Whether the garnishment of the City of Caloocan's funds deposited in a bank
was valid.
Whether the levy and sale of the City's vehicles to satisfy the judgment were
legal.
Whether the auction sale of one of the City's vehicles was tainted with
irregularities.
Whether the former City Mayor's refusal to sign a check for the payment of the
City's obligation constituted contempt of court.
Court's Ruling with Reasoning:
Garnishment of City Funds: The court ruled that while public funds are
generally exempt from garnishment, there is an exception when there is a
corresponding appropriation by law. In this case, the City Council of Caloocan
had approved and passed Ordinance No. 0134, Series of 1992, specifically
allocating the amount for Santiago's back salaries. Therefore, the exception
applied, and the garnishment of the funds was valid.
Levy and Sale of City Vehicles: The court found that the levy on the City's
vehicles had already been lifted by the trial court in an order dated November
10, 1992. Thus, this issue was rendered moot.
Auction Sale of City Vehicle: The court concluded that the auction sale of the
City's vehicle was conducted properly and in compliance with the rules on
public auctions. There was no substantial evidence to prove that the sheriff had
been negligent or that the auction was flawed.
Refusal of Former City Mayor to Sign Check: The court condemned the former
City Mayor's refusal to sign a check for the payment of the City's obligation as a
defiance of judicial processes and a violation of an ordinance he himself
approved. The court emphasized that justice had been served, and it would be
unjust to make Santiago refund the amount already paid to her.
In summary, the court upheld the validity of the garnishment of the City's funds
due to the existence of an appropriation ordinance. It declared the levy and sale
of the City's vehicles moot since the levy had already been lifted. It found no
irregularities in the auction sale of one of the City's vehicles. Finally, the court
criticized the former City Mayor's refusal to sign a check as an act of defiance
and upheld the judgment in favor of Santiago.
RP. V. HIDALGO 12/9/05

Facts of the Case:

1. Tarcila Laperal Mendoza filed a case against the Republic of the


Philippines to annul or declare null and void the title and deed of
sale of a property located in Manila.
2. The case was initially dismissed by another judge on the ground
of state immunity, but the Court of Appeals reversed this
decision.
3. The Supreme Court upheld the Court of Appeals' decision, and
the case was re-raffled to Judge Vicente A. Hidalgo of the
Regional Trial Court (RTC) of Manila, Branch 37.
4. Judge Hidalgo declared the Republic in default for failing to file
an answer within the prescribed period, and he allowed the
plaintiff to present evidence ex parte.
5. Subsequently, Judge Hidalgo rendered a decision in favor of the
plaintiff, ordering the Republic to pay substantial amounts in
compensation, rental, and attorney's fees.
6. The Republic moved for a new trial, arguing that the negligence
of its handling solicitor should not bind the government, and
that the action was barred by prescription and laches.
7. Judge Hidalgo denied the motion for a new trial, and the
Republic's notice of appeal was denied as well.
8. A writ of execution was issued against the Republic, and the
National Treasurer was directed to pay the specified amounts to
the plaintiff.

Main Issues:

1. Whether Judge Hidalgo's actions constituted gross ignorance of


the law, manifest partiality, and conduct prejudicial to the
interest of the service.
2. Whether the issuance of the writ of execution against the
government was proper, considering the exemption of
government funds from execution.
3. Whether the costs of the suit and attorney's fees should have
been imposed on the Republic.
Court's Ruling and Reasoning:

1. The Court found that Judge Hidalgo's actions constituted gross


ignorance of the law, particularly in pronouncing costs against
the government and issuing a writ of execution without due
consideration of the rules and jurisprudence. The Court
emphasized that judges must be conversant with the law, and the
failure to apply basic procedural rules demonstrated a lack of
competence. Judge Hidalgo was fined ₱20,000.00 for gross
ignorance of the law.
2. The Court ruled that the issuance of the writ of execution
against the government was improper. While the government
had consented to be sued, it did not waive its immunity from
execution. Government funds and properties cannot be seized to
satisfy judgments. The Court cited relevant jurisprudence and
administrative guidelines that emphasize the need for judges to
exercise caution and prudence when issuing writs of execution
against government agencies.
3. The Court ruled that the imposition of costs of the suit and
attorney's fees on the Republic was improper. It emphasized that
costs of suit are not recoverable against the government, as
established by law and jurisprudence. Judge Hidalgo's actions in
this regard violated clear legal provisions.

In summary, the Court found Judge Vicente A. Hidalgo


administratively liable for gross ignorance of the law, fined him
₱20,000.00, and warned against further similar acts. The issuance of
the writ of execution against the government and the imposition of
costs and attorney's fees on the Republic were deemed improper and
in violation of established legal principles.

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