**Amado J. Lansang vs. Court of Appeals & Others: A Legal Clarification on the Non-Suitability of the State and the Limits of Official Authority**
### Facts:
In 1970, the General Assembly of the Blind, Inc. (GABI) was allegedly given office, library space, and areas to operate kiosks in Rizal Park by the National Parks Development Committee (NPDC), through an undocumented “verbal agreement”. GABI agreed to remit 40% of its kiosk operations’ profits to NPDC. Following the 1986 EDSA Revolution, NPDC’s new leadership, led by petitioner Amado J. Lansang, initiated a park clean-up. Lansang terminated GABI’s occupation in 1988, citing a breach of their verbal agreement. GABI president Jose Iglesias was deceived into signing a consent for eviction, unaware due to his blindness. Upon receiving eviction notices, GABI sought legal action for damages and an injunction, which resulted in a temporary restraining order (TRO) against the eviction. After the TRO’s expiration, NPDC successfully evicted GABI.
### Procedural Posture:
GABI’s case was dismissed by the RTC, arguing it was essentially against the State which cannot be sued without consent. The Court of Appeals reversed this, finding Lansang personally liable for damages. Lansang’s appeal to the Supreme Court argued the lawsuit was improperly directed at the state and that his actions were legitimate official duties.
### Issues:
1. Whether the Court of Appeals erred in not recognizing the lawsuit against Lansang as essentially a suit against the State.
2. Whether Lansang’s termination of GABI’s concession was valid and performed within his lawful duties.
### Court’s Decision:
The Supreme Court granted Lansang’s petition, setting aside the Court of Appeals’ decision, and affirmed the RTC’s dismissal due to lack of merit. The court clarified that Lansang was sued in his personal capacity for acting with alleged malice and not within his official NPDC duties. It found no substantial evidence of abuse of authority by Lansang or any valid claim for damages by GABI.
### Doctrine:
The doctrine clarified that state immunity does not protect public officials from liability for actions performed in bad faith or beyond their authority. It also established that public spaces cannot be subject to lease agreements, and such accommodations are revocable at the government’s discretion.
### Class Notes:
– **State Immunity**: Public officials cannot be sued for actions within their official duties but are liable personally for acts committed in bad faith.
– **Public Spaces**: Cannot be the object of lease agreements; occupancy at government’s discretion.
– **Doctrine of Authority**: Officials acting beyond their authority or in bad faith are personally liable.
– **Public Official Liability**: Distinction between official capacity (protected by state immunity) and personal capacity (liable for bad faith acts).
– **Revocability of Government Accords**: Verbal agreements with government entities on the use of public property are subject to termination at the government’s discretion.
### Historical Background:
The case reflects the transition and administrative reforms following the 1986 EDSA Revolution, impacting agreements made under previous administrations. It also illustrates the legal boundaries of state immunity and the personal accountability of public officials, providing clarity on the eviction and contractual use of public parks in the Philippines.
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