Philippine Racing Club, Inc. Et Al. vs. Arsenio Bonifacio Et Al.

Facts:
The horse race held in Santa Ana Hippodrome had a faulty start. One of the horses
turned around and blocked the three horses at its left thus enabling the three
horses from the right side to run ahead and gain a good lead. The official starter
signalled the stewards to cancel the race. The two stewards were also acting as
judges. Since his signal was unheeded, the official starter went to the stewards and
told them that in his opinion the race must be cancelled. one of the stewards asked
him to "shut up". When the winning horses were announced, the public showed its
disapproval of the result. Respondents (Commission on Races), convinced that the
race was faulty, decided to cancel it. While the investigation was going on, the
holders of the winning tickets were able to cash the tickets. The company had to
refund to the holders of the losing tickets the sum of P5,032.
Issue: Whether or not the respondents, acting in their capacity as members of the
Commission on Races, should be held liable for the loss sustained by the Company
when it decided to cancel the race.
Held: No. Although the Court said that the respondents, in deciding to cancel the
race, acted in excess of the authority granted to them by law, they could not be
held liable for damages. As a rule, a public officer, whether judicial, quasi-judicial,
or executive, is not personally liable to one injured as a consequence of an act
performed within the scope of his official authority, and in the line of his official
duty. In order that acts may be done within the scope of official authority, it is not
necessary that they be prescribed by statute, or even that they be specifically
directed or requested by a superior officer, but it is sufficient if they are done by an
officer in relation to matters committed by law to his control or supervision, or that
they have more or less connection with such matters, or that they have more or less
connection with such matters, or that they are governed by a lawful requirement of
the department under whose authority the officer is acting.
Where an officer is invested with discretion and is empowered to exercise his
judgment 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 mistaken decision, however
erroneous judgment may be, provided the acts complained of are done within the
scope of the officer's authority, and without willfulness, malice, or corruption.