8/9/2019 Philippine Racing Club

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Philippine Racing Club, Inc. Et Al. vs. Arsenio Bonifacio Et Al.

Facts:

The horse race held in anta Ana !ippodro"e had a fault# start. $ne of the horses

turned around and bloc%ed the three horses at its left thus enabling the three

horses fro" the right side to run ahead and gain a good lead. The o&cial starter

signalled the ste'ards to cancel the race. The t'o ste'ards 'ere also acting as

(udges. ince his signal 'as unheeded, the o&cial starter 'ent to the ste'ards and

told the" that in his opinion the race "ust be cancelled. one of the ste'ards as%ed

hi" to )shut up). *hen the 'inning horses 'ere announced, the public sho'ed its

disapproval of the result. Respondents +Co""ission on Races, convinced that the

race 'as fault#, decided to cancel it. *hile the investigation 'as going on, the

holders of the 'inning tic%ets 'ere able to cash the tic%ets. The co"pan# had to

refund to the holders of the losing tic%ets the su" of P-,/0.

Issue: *hether or not the respondents, acting in their capacit# as "e"bers of theCo""ission on Races, should be held liable for the loss sustained b# the Co"pan#

'hen it decided to cancel the race.

!eld: 1o. Although the Court said that the respondents, in deciding to cancel the

race, acted in e2cess of the authorit# granted to the" b# la', the# could not be

held liable for da"ages. As a rule, a public o&cer, 'hether (udicial, 3uasi4(udicial,

or e2ecutive, is not personall# liable to one in(ured as a conse3uence of an act

perfor"ed 'ithin the scope of his o&cial authorit#, and in the line of his o&cial

dut#. In order that acts "a# be done 'ithin the scope of o&cial authorit#, it is not

necessar# that the# be prescribed b# statute, or even that the# be speci5call#

directed or re3uested b# a superior o&cer, but it is su&cient if the# are done b# ano&cer in relation to "atters co""itted b# la' to his control or supervision, or that

the# have "ore or less connection 'ith such "atters, or that the# have "ore or less

connection 'ith such "atters, or that the# are governed b# a la'ful re3uire"ent of

the depart"ent under 'hose authorit# the o&cer is acting.

*here an o&cer is invested 'ith discretion and is e"po'ered to e2ercise his

(udg"ent in "atters brought before hi", he is so"eti"es called a 3uasi4(udicial

o&cer, and 'hen so acting he is actuall# given i""unit# fro" liabilit# to persons

'ho "a# be in(ured as the result of an erroneous or "ista%en decision, ho'ever

erroneous (udg"ent "a# be, provided the acts co"plained of are done 'ithin the

scope of the o&cer6s authorit#, and 'ithout 'illfulness, "alice, or corruption.