After the Mendiola Massacre, the heirs of the deceased, together with those injured (Caylao group), instituted a petition to seek the reversal of the Orders of respondent Judge Sandoval, which dismissed the complaint for damages against the Republic of the Philippines, on the argument that the State cannot be sued without Its consent. The Supreme Court held that the State did not enjoy immunity in the present case.

The Court listen instances when a suit against the State is proper:

1. When the Republic is sued by name;
2. When the suit is against an unincorporated government agency;
3. When the suit is on its face against a government officer but the case is such that ultimate liability will belong not to the officer but to the government.

In this case, while the Republic in this case is sued by name, the liability does not pertain to the government; but rather, the military officers and personnel. Although the military officers and personnel, then party defendants, were discharging their official functions when the incident occurred, their functions ceased to be official the moment they exceeded their authority the moment they used their firearms against the activists.