Vilas v. Manila - 220 U.S. 345 (1911)
U.S. Supreme Court
Vilas v. Manila, 220 U.S. 345 (1911)
Vilas v. Manila
No. 53, 54, 207
Argued February 24, 27, 1911
Decided April 3, 1911
220 U.S. 345
Even if there is no remedy adequate to the collection of a claim against a governmental subdivision when reduced to judgment, a plaintiff having a valid claim is entitled to maintain an action thereon and reduce it to judgment.
Where the case turned below on the consequence of a change in sovereignty by reason of the cession of the Philippine Islands, the construction of the Treaty with Spain of 1898 is involved, and this Court has jurisdiction of an appeal from the Supreme Court of the Philippine
Islands under § 10 of the Act of July 1, 1902, c. 1369, 32 Stat. 691, 695.
While military occupation or territorial cession may work a suspension of the governmental functions of municipal corporations, such occupation or cession does not result in their dissolution.
While there is a total abrogation of the former political relations of inhabitants of ceded territory, and an abrogation of laws in conflict with the political character of the substituted sovereign, the great body of municipal law regulating private and domestic rights continues in force until abrogated or changed by the new ruler.
Although the United States might have extinguished every municipality in the territory ceded by Spain under the Treaty of 1898, it will not, in view of the practice of nations to the contrary, be presumed to have done so.
The legal entity of the City of Manila survived both its military occupation by, and its cession to, the United States, and, as in law, the present city, as the successor of the former city, is entitled to the property rights of its predecessor, it is also subject to its liabilities.
The cession in the Treaty of 1898 of all the public property of Spain in the Philippine Islands did not include property belonging to municipalities, and the agreement against impairment of property and private property rights in that treaty applied to the property of municipalities and claims against municipalities.
One supplying goods to a municipality does so, in the absence of specific provision, on its general faith and credit, and not as against special funds in its possession, and even if such goods are supplied for a purpose for which the special funds are held, no specific lien is created thereon.
The facts, which involve the liability of the present City of Manila in the Philippine Islands for claims against the City of Manila as it existed prior to the cession under the Treaty of 1898, are stated in the opinion.