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Vilas vs.

City of Manila
220 U.S. 345, April 3, 1911
US Supreme Court


Vilas is a creditor of the City of Manila before the cession of Spain to United States. After
the incorporation, Vilas brought an action to recover the sum of money owed to him by the city.
However, City of Manila contends that the present charter cannot be liable for the
obligations of the old city. Arguing that the situation is analogous to the doctrine of principal and
agent, the death of the principal ending the agency and since the sovereignty of Spain has been
extinguished, it carries with the extinguishment of the old city of Manila.


Whether or not the new city of Manila is liable for the obligations of the old city.


The court ruled that the new city is liable for the obligations of the old city. It held that the
city did not lost its corporate character.
It raised the general rule of public law, recognized and enforced in the US, that whenever
jurisdiction over any territory are transferred from one nation to another, the municipal laws of the
country continue in force. Public property passes from one government to the other, but private
property remains as before. This observed for the protection of private rights.