Roldan v. Philippine Veterans Board
REITERATIONFacts
The Antecedents: Plaintiff Felipe M. Roldan, a first-grade Civil Service eligible, was appointed clerk in the Philippine Veterans Board (PVB) on March 26, 1953. On March 10, 1954, he was advised that his services would terminate effective March 25, 1954, due to his age (57 years old as of March 11, 1953), citing provisions of Act 2589, Cabinet Resolution dated December 23, 1946, and Republic Act 728. Roldan was separated from service, and Juan Domingo was appointed in his stead. Procedural History: Roldan initiated Quo Warranto proceedings against Domingo in Civil Case No. 25603 of the CFI of Manila. The trial court ruled in favor of Roldan, declaring his ouster illegal and ordering his reinstatement. This decision became final and was executed, reinstating Roldan on September 24, 1955. The Petition: Roldan filed the present action against the PVB and its members to recover back wages for the approximately 18 months he was out of service, plus moral damages and attorney's fees. The trial court dismissed the complaint, holding that the PVB was a mere agency of the government, that the salaries were appropriated by law, and that only Congress could appropriate funds for back wages. The court cited Metropolitan Transportation Service (Metran) vs. Paredes.
Issue(s)
Whether the Philippine Veterans Board is a juridical person capable of being sued. Whether the action for back wages against the Philippine Veterans Board and its members constitutes a suit against the State. Whether the plaintiff is entitled to recover back wages and moral damages.
Ruling
The Supreme Court affirmed the decision of the trial court, dismissing the complaint. The Court held that the Philippine Veterans Board is a mere agency of the government, not possessing juridical personality, and therefore cannot be sued without the government's consent. Claims for back wages against such an agency are in effect suits against the government, which require congressional appropriation.
Ratio Decidendi
On the issue of whether the Philippine Veterans Board is a juridical person capable of being sued: The Court held that the Philippine Veterans Board, created under Republic Act No. 65 and functioning under the Department of National Defense, is a mere agency of the government tasked with carrying out the purposes of the Act. It is not a body corporate and politic in deed and in law, and therefore, it does not possess juridical personality. The Court explicitly stated that it "may not considered a juridical person within the meaning of the law, capable of being sued, especially for the recovery of back salaries, which salaries are appropriated only by Congress." This classification is crucial as it determines the Board's capacity to be a party in a lawsuit. On the issue of whether the action constitutes a suit against the State: The Court reiterated the principle that a suit against an officer of a government agency, which would result in a charge against or financial liability to the government, must be regarded as a suit against the government itself. In this case, a judgment in favor of Roldan for back wages would necessarily entail a financial liability against the government. The Court reasoned that "any judgment in favor of Roldan would mean a charge to or a liability against the Philippine Government." Such suits cannot prosper except with the consent of the government, which was not given in this instance. On the issue of entitlement to back wages and moral damages: Since the Philippine Veterans Board is not a juridical person and the suit is considered a suit against the State, the claim for back wages and moral damages cannot be entertained without the government's consent. Furthermore, the Court noted that the salaries of employees of the Board were appropriated annually by law, and the specific salary for Roldan's position during his separation had already been paid to his replacement, Juan Domingo. The Board and its members lacked the authority to provide for the payment of Roldan's back wages, as only Congress possesses the power to make such appropriations. Therefore, Roldan was not entitled to recover the claimed amounts.
Main Doctrine
An agency of the government, not possessing juridical personality, cannot be sued without the government's consent, especially for claims involving back wages which require appropriation by Congress.