Liwayway Vinzons-Chato v · G.R. 141309

Petitioner: Liwayway Vinzons-Chato
Respondent: Fortune Tobacco Corporation
Citation: G.R. No. 141309
Court: Supreme Court En Banc
Division: En Banc
Ponente: Nachura, J.
Decided: December 23, 2008

Summary

This case involved former Internal Revenue Commissioner Liwayway Vinzons-Chato being sued personally by Fortune Tobacco Corporation for damages under Article 32 of the Civil Code. Fortune Tobacco claimed that RMC 37-93, which reclassified their cigarette brands and subjected them to higher taxes, violated their constitutional rights to due process and equal protection. The Supreme Court initially allowed the case to proceed but later reconsidered en banc. The Court held that public officers performing duties owed to the public generally cannot be held personally liable unless the complainant suffers a 'particular or special injury.' Since Fortune Tobacco failed to allege any specific injury beyond vague 'financial difficulties' and had adequate administrative remedies available (which they actually used), the complaint failed to state a cause of action. The case was dismissed, establishing important precedent on the personal liability of public officers performing official duties.

Statutes applied

Civil Code, Art. 32

Related cases

Other Philippine cases on the same provisions and issues.

Rogelio Aberca v. Maj. Gen. Fabian Ver G.R. No. 69866
Supreme Transportation Liner v. Antonio San Andres G.R. No. 200444
Heirs of Eduardo Simon v. Elvin Chan G.R. No. 157547
Calatagan Golf Club v. Sixto Clemente, Jr. G.R. No. 165443
Eli Lui v. Spouses Eulogio G.R. No. 141176
San Ildefonso Lines v. Court of Appeals G.R. No. 119771
Rex G. Rico v. Marciana Q. Deguma G.R. No. 211861
George (Culhi) Hambon v. Court of Appeals G.R. No. 122150

By the Intellegal Editorial Board · December 23, 2008

Search Philippine case law on Intellegal →

AI-assisted case analysis — for research only. Verify against the official decision. A research aid, not legal advice; using this page creates no attorney-client relationship. For legal advice, consult a Philippine lawyer. Verify every holding and citation against the official decision (Supreme Court E-Library / Official Gazette) before relying on it.