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Republic V Judge of CFI of Rizal

The Republic of the Philippines petitioned against a judge's ruling regarding a case involving the Rice and Corn Administration (RCA). The RCA, a government agency, was ordered to pay a supplier money and fees for a corn purchase. The RCA appealed but the judge ruled it had to post an appeal bond. The issue was whether the RCA, as a government agency, was exempt from paying fees and posting bonds. The Supreme Court held that the RCA, having no separate legal identity from the government, was exempt as the government itself is exempt under Philippine law from such requirements.

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270 views1 page

Republic V Judge of CFI of Rizal

The Republic of the Philippines petitioned against a judge's ruling regarding a case involving the Rice and Corn Administration (RCA). The RCA, a government agency, was ordered to pay a supplier money and fees for a corn purchase. The RCA appealed but the judge ruled it had to post an appeal bond. The issue was whether the RCA, as a government agency, was exempt from paying fees and posting bonds. The Supreme Court held that the RCA, having no separate legal identity from the government, was exempt as the government itself is exempt under Philippine law from such requirements.

Uploaded by

Queenie Boado
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines, petitioner, vs Judge of CFI of Rizal, respondent

G.R. No. L-35919 (September 11, 1980) Case Digest


Topic: Government; functions; unincorporated

Facts:
 April 11, 1970, Respondent Sison filed a complaint against Rice & Corn Administration (RCA)
for a sum of money with the Court of First Instance, presided by the respondent Judge.
 The RCA filed a motion to dismiss the said complaint on the ground of non-sustainability of
the RCA as a mere governmental agency but it was denied by the respondent Judge
 May 10, 1972, after trial, the respondent Judge ruled in favor of Sison and ordered the RCA
to pay the corn grains it purchased from Sison (P1,628,451.54) and the attorney's fees
(P250,000.00) and the costs of the suit.
 May 24, 1972, RCA filed a notice of appeal as well as a motion for extension (30 days from
June 16, 1972) within which to file the record on appeal (granted)
 Before expiration of original period to file the record, RCA files its appeal on June 15, 1972
 Sison filed a motion to dismiss the appeal for the RCA's failure to post an appeal bond and
the RCA, represented by the office of the Solicitor General, filed an opposition to Sison's
motion to dismiss the appeal.
 The record on appeal filed by the RCA was approved by the respondent Judge but the RCA's
exemption from the payment of legal fees and from posting of the appeal bond was denied.
 The respondent Judge issued an order giving the RCA 5 days within which to post an appeal
bond. The RCA filed a motion for reconsideration, alleging that they are exempt from
posting an appeal bond.
 Sison filed a motion to dismiss the appeal on the ground of petitioner's refusal to file the
appeal bond.
 The respondent Judge dismissed the RCA's appeal and ruled that the RCA, being a mere
instrumentality of the Government of the Philippines, is not exempt from the payment of
legal fees and from posting of an appeal bond.

Issue:
Whether or not the petitioner RCA (Rice and Corn Administration) is exempt from paying
legal fees and from posting an appeal bond

Held:
Yes. RCA is a governmental agency of Republic of the Philippines without a separate, distinct
and independent legal personality from the latter thus exempt from the payment of legal fees as well
as the posting of an appeal bond. (Legal basis: Under the decisional laws which form part of the legal
system of the PH, the Republic of the PH is exempted; practically a matter of public knowledge and
matter of judicial notice on the part of the courts)

The legal character of RCA was passed upon in the case Ramos vs. Court of Industrial Relations.
In that cited case, the court held:
Congress, by said RA 3452, approved June 14, 1962, created RCA in pursuance of its declared policy
- That in order to stabilize the price of palay, rice and corn, it shall engage in the purchase of
these basic foods directly from those farmers in the Philippines who wish to dispose their
produce at a price that will afford them a fair and just return for their labor and capital
investment.

Therefore, RCA is a governmental machinery to carry out a declared government policy, and not for
profit. It is not possessed of a separate & distinct corporate existence. It is an office directly under
the Office of the President of the Philippines.

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