GP VS MONTE DE PIEDAD

G.R. No. L-9959 December 13, 1916

THE GOVERNMENT OF THE PHILIPPINE ISLANDS, represented by the Treasurer of the Philippine Islands,
plaintiff-appellee,
vs.
EL MONTE DE PIEDAD Y CAJA DE AHORRAS DE MANILA, defendant-appellant.

Facts:

A devastating earthquake took place in the Philippines sometimes in 1863. Contributions amounting to $400,000
were collected during the Spanish regime for the relief of the victims of an earthquake. Out of the aid, $80,000.00
was left untouched. The Monte de Piedad, a charitable institution, in need for more working capital, petitioned the
Governor-General for the transfer of $80,000 as a loan.

In June 1893, the Department of Finance called upon the Monte de Piedad to return the $80,000. The respondent
bank declined to comply with this order upon the ground that only the Governor-General of the Philippine Islands
and not the Department of Finance had the right to order the reimbursement.

On account of various petitions of the persons, the Philippine Islands, through the Attorney-General, bring suit
against the Monte de Piedad for a recover of the $80,000, together with interest, for the benefit of those persons or
their heirs. After due trial, judgment was entered in favor of the plaintiff for the sum of $80,000 gold or its
equivalent in Philippine currency, together with legal interest from February 28, 1912, and the costs of the cause.

The defendant appealed. One of the assignment of errors made by the defendant was to question the competence of
the plaintiff (government) to bring the action, contending that the suit could be instituted only by the intended
beneficiaries themselves or by their heirs.

Issues:

Whether or not the Philippine government is competent to file a complaint against the respondent bank for the
reimbursement of the money of the intended beneficiaries?

Discussions:

In accordance with the doctrine of Parens Patriae. The government being the protector of the rights of the people has
the inherent supreme power to enforce such laws that will promote the public interest. No other party has been
entrusted with such right hence as “parents” of the people the government has the right to take back the money
intended for the
Rulings:

Yes. The Supreme Court upheld the right of the Government to file the case as parens patriae in representation of the
legitimate claimants. The legislature or government of the State, as parens patriae, 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.

This prerogative of parens patriae is inherent in the supreme power of every State, whether that power is lodged in a
royal person or in the legislature. It is a most beneficient functions, and often necessary to be exercised in the
interest of humanity, and for the prevention of injury to those who cannot protect themselves. The beneficiaries of
charities, who are often in capable of vindicating their rights, and justly look for protection to the sovereign
authority, acting as parens patriae. They show that this beneficient functions has not ceased to exist under the change
of government from a monarchy to a republic; but that it now resides in the legislative department, ready to be called
into exercise whenever required for the purposes of justice and right, and is a clearly capable of being exercised in
cases of charities as in any other cases whatever.