Title: Bacani vs National Coconut
Corp
Cause of Action:
Case Number:
Date:
Doctrine:
Full Text:
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Full Text\G.R. No. L-9657 - Bacani vs. National Coconut Corp_.pdf
Overview:
A dispute arises over whether the National Coconut Corporation is exempt from paying
stenographers' fees, with the court ruling in favor of the stenographers and clarifying
that the corporation is not considered a government entity for the exemption.
Facts:
Plaintiffs: Leopoldo T. Bacani and Mateo A. Matoto, court stenographers assigned
to Branch VI of the Court of First Instance of Manila.
Case: Civil Case No. 2293, Francisco Sycip vs. National Coconut Corporation.
Request: Assistant Corporate Counsel Federico Alikpala requested copies of the
transcript of stenographic notes.
Compliance: Bacani and Matoto delivered a 714-page transcript and submitted
bills for payment.
Payment: National Coconut Corporation paid Bacani P564 and Matoto P150 at P1
per page.
Disallowance: Auditor General disallowed the payments, citing a Department of
Justice circular exempting the National Coconut Corporation from such fees.
Action: Auditor General ordered salary deductions to reimburse the fees.
Plaintiffs' Response: Filed an action to prevent deductions and obtain a ruling
that the National Coconut Corporation is not a government entity under section 16,
Rule 130 of the Rules of Court.
Lower Court Ruling: Ruled in favor of plaintiffs, declaring the National Coconut
Corporation is not a government entity for exemption purposes and that the
payments were valid and legal.
Appeal: Defendants appealed the decision.
Issue:
1. Government Entity Status: Is the National Coconut Corporation considered a
government entity under section 16, Rule 130 of the Rules of Court, thereby
exempting it from paying stenographers' fees?
2. Payment Validity: Are the payments made to the stenographers at a rate of P1
per page valid even though they exceed the prescribed limit in section 8, Rule 130
of the Rules of Court?
Ruling:
1. Government Entity Status: The Supreme Court ruled that the National Coconut
Corporation is not considered a government entity under section 16, Rule 130 of
the Rules of Court and is therefore not exempt from paying stenographers' fees.
2. Payment Validity: The payments made to the stenographers at a rate of P1 per
page were deemed valid and contractual, even though they exceeded the limit
prescribed by section 8, Rule 130 of the Rules of Court.
Ratio:
Definition: The term "Government of the Republic of the Philippines" in section 2
of the Revised Administrative Code refers to entities through which governmental
functions are exercised as an attribute of sovereignty, including provincial,
municipal, or other forms of local government.
Municipal Corporations: These entities are considered municipal corporations.
Government-Owned Corporations: Government-owned or controlled
corporations like the National Coconut Corporation have a separate corporate
personality governed by the Corporation Law and do not fall under the definition of
a government entity.
Exemption: The National Coconut Corporation does not qualify for the exemption
from legal fees provided in section 16, Rule 130 of the Rules of Court.
Payment Agreement: Although section 8, Rule 130 prescribes specific rates, the
National Coconut Corporation agreed to pay and did pay P1 per page for the
services rendered.
Contractual Validity: The agreement was not contested until the Auditor
General's intervention, making the payment contractual and valid, even if it
exceeded the prescribed limit.
Procedural Issue: The Court dismissed the procedural issue raised by the
appellants, noting that the case was an action of prohibition to prevent salary
deductions, not an appeal from a decision of the Auditor General.
Wherefore, the decision of the lower court was affirmed, with no pronouncement as to
costs.
