Facts:

Sabas Torralba was employed as the driver of Ilocos Norte and detailed to the Office
of the District Engineer. While driving his truck, Sabas ran over Proceto Palafox
resulting to the latters death. Sabas was prosecuted for homicide through reckless
imprudence to which he pleaded guilty. The heirs of Palafox instituted a civil case
against him, the Province, the District Engineer and the Provincial Treasurer.
Issue:
Whether or not the Province of Ilocos Norte can be held liable.
Held:
NO. The general rule is that local government units are not liable for negligent acts
of its employees while they are performing governmental functions or duties. In this
case, the driver was involved in the construction or maintenance of roads which was
a governmental duty. Therefore, the province cannot be held liable for his negligent
act. However tragic and deplorable it may be, the death of Palafox imposed on the
province no duty to pay monetary consideration. (Palafox v. Province of Ilocos
Norte, 102 Phil 1186)

Sanders v. Veridiano
Sanders v. Veridano
GR No. L-46930; June 10, 1988
FACTS:
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
gameroom 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 officers report of the reinstatement of
private respondents to permanent full-time status plus backwages. Respondents
allege that the letters contained libellous imputations which caused them to be
ridiculed and thus filed for damages against petitioners.
ISSUE:
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?
HELD:
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 petioners 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 Unites 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.