Government of the Philippine Islands vs Monte de Piedad

G.R. No. 9959

35 PH 728, 751-753

December 13, 1916

Petitioner: Government of the Philippine Islands, represented by Executive Treasurer

Respondent: El Monte de Piedad Y Caja de Ajorras de Manila

FACTS: On June 3, 1863, a devastating earthquake in the Philippines took place. The Spanish dominions provided $400,000 aid as received by the National Treasury as relief of the victims of the earthquake. The government used the money as such but $80,000 was left untouched and was thus invested to Monte de Piedad bank, which was in turn invested as jewelries, equivalent to the same amount. 

In June 1983, the Department of Finance called upon the same bank to return the $80,000 deposited from before. The Monte de Piedad declined to comply with this order on the ground that the Governor-General of the Philippine Islands and not the Department of Finance had the right to order the reimbursement because the Philippine government is not the affected party. On account of various petitions of the persons, the Philippine Islands brought a suit against Monte de Piedad for a recovery of the $80,000 together with interest, for the benefit of those persons and their heirs. Respondent refuse to provide the money, hence, this appeal.

ISSUE: Whether or not the Philippine government is authorized to file a reimbursement of the money of the people deposited in respondent bank. 

HELD: The Court held that the Philippine government is competent to file a complaint/reimbursement against respondent bank in accordance to the Doctrine of Parens Patriae. The government is the sole protector of the rights of the people thus, it holds an inherent supreme power to enforce laws which promote public interest. The government has the right to "take back" the money intended fro people.   The government has the right to enforce all charities of public nature, by virtue of its general superintending authority over the public interests, where no other person is entrusted with it.  

Appellate court decision was affirmed. Petition was thereby GRANTED. The Court ordered that respondent bank return the amount to the rightful heirs with interest in gold or coin in Philippine peso.

• Constitutional Law 1: State Functions / Concept of State (Textbook: Cruz, Professor: Atty. Usita)

♥ Reese Corpuz