Wylie vs.

Rarang
G.R. No. 74135 | 28 May 1992
Ponente: Justice Gutierrez, Jr.
Topic: Extent of the "immunity from suit" of the officials of a United States Naval B ase inside

Philippine territory
FACTS:
As assistant administrative officer of the US Naval Station, Wylie was tasked, among other things, to
supervise the publication of the Plan of the Day (POD); the POD feature important news,
announcements, warnings, etc., that were of interest to the military. And one of their regular features was
the action line inquiry. On 3 Feb 1978, the POD published under the said section an inquiry regarding
theft wherein Aurora Rarang was implicated and identified. Four days later, Wylie wrote her an apology.
Rrarang however went to the Court of First Instance and filed a case asking for indemnity against Wylie,
and his superior, Capt. Williams. Wylie and Williams responded by filing a motion to dismiss.
Unfortunately, the trial court denied their petition and ruled in favor of Rarang.
They appealed to the Intermediate Appellate Court (Court of Appeals), but their petition was again
denied. Simultaneous with their appeal, was Rrarangs appeal as she was not satisfied with the amount of
damages given to her. Fortunately for her, the appellate court granted her appeal, increasing the amount
that Wylie and Williams are obligated to pay.
Discontented with the ruling of the appellate court, the defendant filed a petition o the Supreme Court.
ISSUES:
Whether or not the American naval officers who commit a crime or tortious act while discharging official
functions still covered by the principle of state immunity from suit (pursuing the question further, does
the grant of rights, power, and authority to the United States under the RP-US Bases Treaty cover
immunity of its officers from crimes and torts).
RULING:
No.
The court opined that our laws, and presumably, those of the United States, forbid the performance of
offenses under the guise of official duty. The court cites the case of Chavez vs. Sandiganbayan, which
maintained that, public officials can be held personally accountable for acts claimed to have been
performed in connection with official duties where they have acted ultra vires or where there is showing
of bad faith. In the case at bar, the court ruled that Wylie and Williams committed an act of defamation
against Rarang; further, they also committed negligence as they did not omit the name Auring in the
article in the said publication.
The court denies the petition.