Republic vs. Judge, Branch XV (Consti1)

Republic of the Philippines, petitioner, vs. The Presiding Judge, Branch XV, Court of First Instance of Rizal and Jose Sison, respondents.

September 11, 1980

De Castro, J:

Facts:

• Respondent Jose Sison filed a complaint against the petitioner Rice and 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 complaint but it was denied by the respondent Judge.
• After a trial, the respondent Judge ruled in favor of Sison and ordered the RCA to pay the corn grains it purchased from Sison and the attorney's fees and the costs of the suit.
• The RCA later on filed its record on appeal.
• 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 is exempt from paying legal fees and from posting an appeal bond.

Held:

• Yes

Ratio:

• RCA is a governmental agency of Republic of the Philippines without a separate, distinct and independent legal personality from the latter. And, as a governmental agency under the Office of the President, the RCA is thus exempt from the payment of legal fees and from posting of an appeal bond.