WYLIE V. RARANG J.

GUTTIEREZ POLITICAL LAW DOCTRINE OF STATE IMMUNITY

FACTS:

Wylie, assistant administrative officer of US Naval Station in Subic Bay, supervise the daily
publication of PLAN OF THE DAY (POD) in the US Naval Station.
Navista Action Line section was published in the POD on Feb 3, 1978 saying that a Merchandise
Control inspector are consuming for their own benefit things that honesty, they have
confiscated from base personnel and mentioned a certain Auring is being a disgrace to her
division and to the office of the Provost Marshall.
Rarang filed a complaint, her being the only Auring in their office, Provost Marshall, alleging that
the article is false, injurious and malicious defamation and libel against her despite of the letter
their office sent to Wylie stating that if the article were to be published, omit the name
Auring. She prayed to be awarded damages. Petitioners are sued in their personal capacities
for their alleged tortious act.
Defendants filed a motion to dismiss on the ground that they acted within the performance of
their official functions therefore immune from suit and US Naval Base is an instrumentality of
the US Government which cannot be sued without its consent.
Motion to Dismiss was DENIED.

ISSUE:

WON Wylie and Williams is a public official that may invoke immunity from suit

HELD:

RTC= held in favor of RARANG.

o Their act was a personal and tortious acts which are exception to the general rule that
a sovereign country cannot be sued in another country without its consent, their acts
and ommissions are done in the personal and individual capacities.
CA= on appeal, RTC decision is affirmed with modification and increased in damages.
SC= CA affirmed
o Wylie and Williams participated in the screening of the articles before the publication,
as part of their official function.
o Laid out the doctrine of Chavez v. Sandiganbayan regarding immunity from suit of
Public Officials, the general rule is that public officials can be held personally
accountable for acts claimed to have been performed in connection with official duties
where they have acted showing bad faith.
o Petitioners were negligent for not deleting Auring upon the request, classified a s a
tortious act.