Background

The case revolves around employees of the Philippine Normal College seeking compensation for salary differentials and overtime pay. Their lawsuit was initially dismissed on the grounds that the college lacked the juridical capacity to be sued. This dismissal led to an appeal to the Supreme Court, where the central question became whether the Philippine Normal College could indeed be sued as a juridical entity.

Facts

• 1. Twenty employees of the Philippine Normal College worked in various capacities in its dormitory, Normal Hall.
• 2. The employees filed an action for the recovery of salary differentials and overtime pay.
• 3. The Court of First Instance dismissed the case, stating that neither defendant was a corporation or juridical entity with the capacity to be sued.
• 4. The plaintiffs appealed this dismissal to the Supreme Court.

Arguments of the Petitioners

• 1. The Court of First Instance erred in dismissing their case on the ground that the defendants lacked juridical capacity to be sued.
• 2. The Philippine Normal College, as converted from the Philippine Normal School by Republic Act No. 416, has the capacity to be sued.

Arguments of the Respondents

• 1. The Solicitor General, representing the defendants, denied liability.
• 2. While admitting that the Philippine Normal College has a juridical personality, the Solicitor General argued that as an instrumentality of government for the discharge of state functions, it may not be sued without the consent of the state.

Issues

• 1. Does the Philippine Normal College have the juridical capacity to be sued?
• 2. Has the state given consent for the Philippine Normal College to be sued?

Ruling

• 1. The Supreme Court ruled that the Philippine Normal College does have the juridical capacity to be sued.
• 2. The Court held that the state had already given consent for the College to be sued by investing it with the express power to be sued in courts.

Rationale

• 1. Republic Act No. 416 converted the Philippine Normal School into the Philippine Normal College and endowed it with the general powers set out in section 13 of Act No. 1459 (Corporation Law).
• 2. One of the powers specifically enumerated in section 13 of the Corporation Law is the power "to sue and be sued in any court."
• 3. The express grant of power to sue and be sued indicates that the Philippine Normal College could be made a defendant in a suit in court.
• 4. The state's consent for the College to be sued is evident in the express power given to it to be sued in courts.
• 5. Section 6 of Republic Act No. 416 provides that "all process against the Board of Trustees shall be served on the President or secretary thereof," further indicating that the Act authorizes the College to be sued.

Doctrines

• 1. Juridical Personality: The case reinforces the principle that institutions created by law can have juridical personality separate from the government, with the capacity to sue and be sued.
• 2. State Consent to be Sued: The doctrine that the state's consent is necessary to sue government instrumentalities is discussed, with the Court clarifying that such consent can be given through express statutory provisions.