Brief Fact Summary.

When Ruizs sentence was vacated because she refused to waive her
rights to impeachment evidence, the government brought appeal on the grounds that its plea
bargaining
process
was
not
unconstitutional.
Synopsis of Rule of Law. While the Fifth and Sixth Amendments require that a defendant
receive exculpatory evidence at trial, a defendant may waive their right to this information in a
plea agreement.
Facts. Federal prosecutors offered respondent, Angela Ruiz, a fast track plea bargain, after 30kg
of marijuana was found in her luggage by immigration agents. Per the terms of the bargain, the
respondent would have gotten a reduced sentence recommendation, in exchange for waiving the
right to receive impeachment information relating to any informants or other witnesses, as well
as to information supporting any affirmative defense she may raise if she were to go to trial. Ruiz
rejected the waiver of her rights, the offer was withdrawn and she was indicted for unlawful drug
possession. At sentencing, Ruiz asked the judge to grant her the sentence she would have gotten,
had she taken the plea bargain, on the grounds that it was in violation of her Fifth and Sixth
Amendment rights to a fair trial. The Court of Appeals ruled for the respondent, and vacated the
sentence,
and
the
government
brought
appeal.
Issue. Whether, before entering into a plea agreement, the Fifth and Sixth Amendments require
federal prosecutors to disclose impeachment information relating to informants or other
witnesses.
Held. Justice Breyer, for the Court, held that although the Fifth and Sixth Amendments do
provide that a defendant be given exculpatory impeachment evidence from prosecutors, a guilty
plea under a plea agreement, with a waiver of rights, can be accepted as knowing and voluntary.
Concurrence. Justice Thomas concurs, noting that the purpose of requiring exculpatory evidence
is so there be no unfair trial to the accused, which does not apply at the plea bargaining stage.
Discussion. While the Fifth and Sixth Amendments are designed to protect the right to a fair
trial, a defendant can knowingly and voluntarily waive those rights in a valid plea agree

Tuesday, July 28, 2009

US Vs. Ruiz 136 SCRA 487
Facts:
The usa had a naval base in subic, zambales. The base was one of those provided in the military
bases agreement between phils. and the US. Respondent alleges that it won in the bidding
conducted by the US for the constrcution of wharves in said base that was merely awarded to
another group. For this reason, a suit for specific preformance was filed by him against the US.
Issue: Whether the US naval base in bidding for said contracts exercise governmental functions
to
be
able
to
invoke
state
immunity.
Held:
The traditional role of the state immunity excempts a state from being sued in the courts of
another state without its consent or waiver. This rule is necessary consequence of the principle of
indepemndence and equality of states. Howecer, the rules of international law are not petrified;
they are continually and evolving and because the activities of states have multiplied. It has been
necessary to distinguish them between sovereign and governmental acts and private, commercial
and proprietory acts. the result is that state immunity now extends only to sovereign and
governmental
acts.
The restrictive application of state immunity is proper only when the proceedings arise out of
commercial transactions of the foreign sovereign. Its commercial activities of economic affairs.
A state may be descended to the level of an individual and can thus be deemed to have tacitly
given its consent to be sued. Only when it enters into business contracts. It does not apply where
the conracts relates the exercise of its sovereign function. In this case, the project are integral part
of the naval base which is devoted to the defense of both US and phils., indisputably, a function
of the government of highest order, they are not utilized for , nor dedicated to commercial or
business purposes.

USA vs. Ruiz G.R. No. L-35645, May 22, 1985

Sunday, January 25, 2009 Posted by Coffeeholic WritesLabels: Case Digests, Political Law
Facts:
The US had a naval base in Subic, Zambaleswhich was one of those provided in the Military
Bases Agreement between the Phils. and the US. The US made an invitation for the submission
of bids for the repair of wharves in said base. Private respondent Eligio de Guzman& Co., Inc.
responded to the invitation and submitted bids. Subsequent thereto, the private respondent
received from the US 2 telegrams requesting it to confirm its price proposals and for the name of
its bonding company. The private respondent complied with the requests. Thereafter, private
respondent received a letter which said that the company did not qualify to receive an award for
the projects because of its previous unsatisfactory performance rating. The private respondent
sued the US and the members of the Engineering Command of the US Navy.
Issue:
Whether or not the complaint may prosper
Held:
The traditional rule of State immunity exempts aState from being sued in the courts of another
State without its consent or waiver. This rule is a necessary consequence of the principles of
independence and equality of States. However, the rules of International Law are not petrified;
they are constantly developing and evolving. And because the activities of states have multiplied,
it has been necessary to distinguish them necessary to distinguish between sovereign and
governmental acts (jure imperii) and private, commercial and proprietary acts (jure gestionis).
The result is that State immunity now extends only to acts jure imperii.
A State may be said to have descended to the level of an individual and can thus be deemed to
have tacitly given its consent to be sued only when it enters into business contracts. It does not
apply where the contract relates to the exercise of its sovereign functions. In the present case,
the projects are an integral part of the naval base which is devoted to the defense of both the US
and the Phils.,indisputably a function of the government of the highest order. They are not
utilized for nor dedicated to commercial or business purposes.

USA v. RUIZ
GR No. L-35645; May 22, 1985
FACTS:
Sometime in May 1972, the United States invited the submission of bids for certain naval
projects. Eligio de Guzman & Co. Inc. responded to the invitation and submitted bids.
Subsequently, the company received two telegrams requesting it to confirm its price. In June
1972, the copany received a letter which said that the company did not qualify to receive an
award for the projects. The company then sued the United States of America and individual
petitioners demanding that the company perform the work on the projects, or for the petitioners
to pay damages and to issue a writ of preliminary injunction to restrain the petitioners from
entering into contracts with third parties concerning the project.
ISSUE:
1) Do the petitioners exercise governmental or proprietary functions?
2) Does the Court have jurisdiction over the case?
HELD:
The rule of State immunity exempts a State from being sued in the courts of another state
without its consent or waiver. This is a necessary consequence of the principles of independence
and equality of states. However, state immunity now extends only to governmental acts of the
state. The restrictive application of State immunity is proper only when the proceedings arise out
of commercial transactions of the foreign sovereign. In this case, the projects are integral part of
the naval base which is devoted to the defense of the USA and Philippines which is, indisputably,
a function of the government. As such, by virtue of state immunity, the courts of the Philippines
have no jurisdiction over the case for the US government has not given consent to the filing of
this suit.