GR No. L-46930; June 10, 1988
Petitioner Dale Sanders was the special services of the US Naval Station (NAVSTA) in Olongapo city. Private respondents Anthony Rossi and Ralph Wyers are American citizens permanently residing in the Philippines and who were employed as game room attendants in the special services department of NAVSTA. On October 3, 1975, the respondents were advised that their employment had been converted from permanent full-time to permanent part-time. In a letter addressed to petitioner Moreau, Sanders disagreed with the hearing officer’s report of the reinstatement of private respondents to permanent full-time status plus backwages. Respondents allege that the letters contained libelous imputations which caused them to be ridiculed and thus filed for damages against petitioners.
1) Were the petitioners acting officially or only in their private capacities when they did the acts for which the private respondents sued them for damages?
2) Does the court have jurisdiction over the case?
It is abundantly clear in the present case that the acts for which the petitioner are being called to account were performed by them in the discharge of their official duties. Given the official character of the letters, the petitioners were, legally speaking, being sued as officers of the United States government. As such, the complaint cannot prosper unless the government sought to be held ultimately liable has given its consent to be sued. The private respondents must pursue their claim against the petitioners in accordance with the laws of the United States of which they are all citizens and under whose jurisdiction the alleged offenses were committed for the Philippine courts have no jurisdiction over the case.