2
MIJARES V. RANADA
Date: April 12, 2005
Article III Primacy of Human Rights and
Enforcement
Petitioners: PRISCILLA C. MIJARES, LORETTA
ANN P. ROSALES,
HILDA B. NARCISCO, SR., MARIANI
DIMARANAN,
SFIC, and JOEL C. LAMANGAN
GR 139325
Rica Aggabao
Tinga, J.
Respondents: HON. SANTIAGO JAVIER
RANADA, in his capacity as
Presiding Judge of Branch 137, Regional Trial
Court,
Makati City, and the ESTATE OF FERDINAND
E.
MARCOS
Doctrine: Alien Tort Act
- A suit by aliens for tortious violations of international law (Filipinos suing Marcos in
US District Court on abuses during his regime)
Facts:
1. Petitioners are victims of human rights abuses during the Marcos Regime. They were
representing 10, 000 other citizens who were victimized under said period.
2. They came to the US District Court against the estate of Marcos.
3. Alien Tort Act is being invoked for basis of US District Court’s jurisdiction because it is a
suit filed by aliens for violations of international law.
4. US District Court ruled in favor of the victims and awarded them $1,964,005,859.90 as
damages.
5. Present petitioners filed complain with Makati RTC for enforcement of the US District
Court judgment. Respondents, the Marcos Estate, filed a motion dismiss because of
petitioners’ failure to pay filing fees.
6. Petitioners claim that the subject matter is the enforcement of judgment, not collection
of damages. RTC judge Javier however ruled that the subject matter is capable of
monetary estimation because of the amount quoted in the foreign judgment, allowing
easy determination of value.
7. Petitioners filed an MR which Judge Ranada denied, which brought them to file a petition
for certiorari.
1.
Issue/s:
1. W/N US Judgment is enforceable in Philippine Jurisdiction
Ruling:
1. YES
Rationale/Analysis/Legal Basis:
1. US District Court decision falls under GAPOIL, which is incorporated in the law of the
land.
The right to seek recognition and enforcement of foreign judgments, as well as a
right to defend against such enforcement is recognized in the Philippine legal system.
Preclusion of an action for enforcement of a foreign judgment in the Philippines merely due to
incorrect filing fees is contrary to the general principles of international law; hence, it cannot
be used as a ground to dismiss the case.
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