The Philippine Racing Club held a horse race that had a faulty start, with some horses getting an unfair advantage. When the official starter signalled to cancel the race, one steward told him to continue it. After the race, the betting public was upset by the result. The Commission on Races investigated and decided to cancel the race. They refunded losing bets but winners had already cashed their tickets. The Club sued the Commission to recover costs. The court found that while the Commission exceeded its authority in cancelling the race, the members acted in good faith within their duties and are immune from liability for damages resulting from erroneous decisions.
Original Description:
public officer-phil racing club vs bonifacio
Original Title
Public Officer-Philippine Racing Club vs Bonifacio
The Philippine Racing Club held a horse race that had a faulty start, with some horses getting an unfair advantage. When the official starter signalled to cancel the race, one steward told him to continue it. After the race, the betting public was upset by the result. The Commission on Races investigated and decided to cancel the race. They refunded losing bets but winners had already cashed their tickets. The Club sued the Commission to recover costs. The court found that while the Commission exceeded its authority in cancelling the race, the members acted in good faith within their duties and are immune from liability for damages resulting from erroneous decisions.
The Philippine Racing Club held a horse race that had a faulty start, with some horses getting an unfair advantage. When the official starter signalled to cancel the race, one steward told him to continue it. After the race, the betting public was upset by the result. The Commission on Races investigated and decided to cancel the race. They refunded losing bets but winners had already cashed their tickets. The Club sued the Commission to recover costs. The court found that while the Commission exceeded its authority in cancelling the race, the members acted in good faith within their duties and are immune from liability for damages resulting from erroneous decisions.
Arsenio Bonifacio, et al., respondents G.R. No. L-11944 August 31, 1960
Facts: In a race held at the Sta. Ana Hippodrome belonging to the
Philippine Racing Club., Inc, the competing horses went off to a faulty start. When the barrier was lifted, one of the horses turned around and blocked the three horses at its left thus enabling the three horses on the right side to run ahead and gain a good lead. The official starter signalled the stewards of the races indicating the race should be cancelled. The two stewards on duty were also acting as judges. As his signal went unheeded, the official starter went to the stewards to inform them that the start was bad and in his opinion, the race should be cancelled. However, one of the stewards told him to shut up and allowed the race to on until its termination. When the winning horses were announced, the betting public showed its disapproval of the result. This resulted in a commotion which reached the knowledge of the members of the Commission on Races. When they noticed the uproar and were informed of its cause, they sent for the stewards and made an on the spot investigation. Convinced that the start of the race was faulty, they decided to cancel it and had their decision announced to the public. However, while the investigation was going on, the holders of the winning tickets were able to cash the same. The Club paid the dividends on the winning tickets and refund to the holders of the losing ones the sum of P5,032.00 Thus, the petitioner seek to recover from respondents the said sum of P5,032.00 plus damages. But the respondents disclaimed responsibility since they annulled the race only because they did it so merely pursuant to their official duties as members of the Commission on Races. Issue: Whether or not the Commission on Races, should be held liable for the loss sustained by the Club when it decided to cancel the race? Held: No. The action taken by the Commission on Races of cancelling or annulling the race for the reason that there was a faulty start was in excess of the authority granted to it by law. However, considering that the respondents have acted in their official capacity in the honest belief that they had such power as in fact they acted on the matter only after an on the spot investigation, they cannot be held liable for damages. Where an officer is invested with discretion and is empowered to exercise his judgement in matters brought before him, he is sometimes called a quasi-judicial officer, and when so acting he is actually given immunity from liability to persons who may be injured as the result of
an erroneous or mistake decision, however erroneous judgement may
be, provided the acts complained of are done within the scope of the officers authority, and without wilfulness, malice or corruption.