Government of the Philippine Islands v. El Monte De Piedad

TOPICS: parens patriae

FACTS: 

In 1863 the inhabitants of the Spanish dominions contributed funds for the relief of those damaged by an earthquake in the Philippine Islands and the money worth $80,000.00 was remitted to the Philippines to be distributed by a central relief board.

Part of the funds contributed were turned over to the board. Part of the funds contributed were turned over to the "Monte de Piedad," an institution under the control of the church, to be held at the disposal of the relief board. Subsequently, Spain relinquished Philippines to the United States  through the Treaty of Paris. However, the money was not passed to the USA.  

ISSUE:

WON the Philippine government is proper party to maintain an action to recover the funds. 

RULING:

Yes, the Philippine Government is the proper party to maintain an action to recover the funds thus loaned or deposited for the purpose of carrying out the intention of the contributors. 

The State as a sovereign, is the parens patriae. It has the right to enforce all charities of public nature by virtue of its general superintending authority over the public interests, where no other person is entrusted with it. It is the most beneficient function, and often necessary to be exercised in the interest of humanity, and for the prevention of injury to those who cannot protect themselves.

In this case, the contributors of the money, who could claim to be damaged by the payment to the Monte, do not appear on record. The beneficiaries, consisting of the original sufferers and their heirs, are numerous. A large number of original victims died and their heirs can no longer be ascertained. Hence, it is the Philippine government, in view of parens patriae, who could enforce all charities. 

Therefore, the Philippine government is proper party to maintain an action to recover the funds