Syquia v.

Almeda Lopez (Estoppel government)

DOCTRINE: Substance over form when determining the real parties in a case.

FACTS:
The US government were leasing 3 apartments jointly owned by the Syquias (North, South, and
Michael apartments) to house troops with the agreement that the lease was to be for the duration of
the war (WWII) and six months thereafter, unless sooner terminated by the US.
Six months after September 2, 1945, when Japan surrendered, plaintiffs approached the defendants
Moore and Tillman and requested the return of the apartment buildings, but Moore and Tillman
expressed to plaintiffs that the US Army wanted to continue occupying the premises.
Plaintiffs requested to renegotiate said leases, but respondents refused to do so and told them that the US
Army will vacate the apartments before February 1, 1947.Because of the assurance that the US Government
would vacate the premises before February 1, 1947, the plaintiffs took no further steps to secure possession of the
buildings continued the old lease terms
On February 17, 1947, plaintiffs served a formal notice to the occupants demanding: (a) cancellation
of said leases; (b) increase in rentals to P300 a month; (c) execution of new leases (d)release of said
apartment buildings within thirty days of said notice in the event of failure to comply with said demands.
Plaintiffs commenced an action in the Municipal Court of Manila in the form of an action for Unlawful
Detainer against respondents.
Respondents filed a Motion to Dismiss on the grounds that the court had no jurisdiction over the defendants, the war
between the US and her allies on one side and Germany and Japan on the other had not yet been terminated at
the time of questioning, while also invoking the non-suability clause (claimed US government is the real party to the case.

ISSUE: WON the US government is the real party to the case at hand, and WON the Municipal Court of Manila
has jurisdiction over the case at hand.

HELD: YES and NO, respectively

SC: We are convinced that the real party in interest as defendant in the original case is the United
States of America.
o The considerations or rentals were always paid by the U. S. Government
o There is no other logical party to be held liable since:
Moore and Tillman were only implementing the obligations constructed by their
predecessors
The 64 officers who lived there were just assigned the apartments in question as
living quarters and did not actually get to choose
Since it is really a suit against the government, more so since it is a foreign government, the court
does not have jurisdiction over the case

DISSENTING (Perfecto)
No question that the court has complete jurisdiction of the case
o Since the US government executed a private contract of lease with private lessors, it put
itself at equal footing with such lessors, and thus can be sued as a lessee
Once a foreign government enters into a private contract with the private citizens of another
country, such foreign government cannot shield its non-performance or contravention of the terms
of the contract under the cloak of non-jurisdiction.
o To concede to such will give approval to the execution of unilateral contracts
o Contratos Leoninos: One party in the contract getting the Lions share of the agreement
o To give validity to such sanctifies bad faith, deceit, and fraud
SC: We cannot believe that said government is so callous as not to understand the meaning of the
shame entailed in the legal stand of non-jurisdiction intended to place said government beyond the
reach of our courts of justice.