Case Digest (G.R. No. 83831)
Facts:
The case involves four consolidated petitions filed before the Supreme Court of the Philippines, specifically G.R. Nos. 83831, 85594, 85597, and 85621, all decided on January 9, 1992. The primary parties include Victor Africa as the petitioner in G.R. No. 83831, and the Presidential Commission on Good Government (PCGG) along with its nominees/designees as respondents. The backdrop of the case is the sequestration of Eastern Telecommunications Philippines, Inc. (ETPI) by the PCGG on March 14, 1986, which was part of the government's efforts to recover ill-gotten wealth associated with former President Ferdinand Marcos and his associates. Following the sequestration, a partial lifting occurred in May 1986, allowing 40% of the shares owned by Cable and Wireless, Ltd. to be freed, while 60% remained under sequestration.
On July 22, 1987, the PCGG filed Civil Case No. 0009 in the Sandiganbayan for reconveyance, reversion, accounting, restitution of the alleged ill-gotten ETP...
Case Digest (G.R. No. 83831)
Facts:
Sequestration of ETPI: The Presidential Commission on Good Government (PCGG) sequestered Eastern Telecommunications Philippines, Inc. (ETPI) on March 14, 1986, alleging the shares were ill-gotten. In May 1986, 40% of the shares (Class B) owned by Cable and Wireless, Ltd. were released from sequestration, while the remaining 60% (Class A) remained under sequestration.
Filing of Civil Case No. 0009: On July 22, 1987, PCGG filed Civil Case No. 0009 in the Sandiganbayan, seeking reconveyance, reversion, accounting, restitution of the ETPI shares, and damages.
Stockholders’ Meeting and Board Elections: During the annual stockholders’ meeting on January 29, 1988, Eduardo M. Villanueva (PCGG nominee), Roman Mabanta, Jr., and Eduardo de los Angeles (foreign investors’ nominees) were elected to the ETPI board. Villanueva was later elected president and general manager.
Victor Africa’s Petition (G.R. No. 83831): Victor Africa, claiming to be ETPI’s vice-president and corporate secretary, filed a petition for injunction on June 30, 1988, seeking to stop his ouster from his positions. He alleged that the PCGG-sponsored board’s actions were arbitrary and intended to harass him.
Civil Case No. 0048: Jose L. Africa, Manuel Nieto, and Rafael Valdez filed a complaint for injunction and damages against Villanueva and the PCGG on September 6, 1988, challenging Villanueva’s election as director and president, claiming it was done without due process.
Civil Case No. 0050: The same plaintiffs filed another complaint on September 23, 1988, questioning the election of PCGG nominees to the ETPI board and seeking their removal.
Subpoena Issues: The Sandiganbayan issued subpoenas for ETPI’s stock and transfer book and meeting minutes, which the PCGG sought to quash.
Appeals to the Supreme Court: The PCGG and Villanueva filed petitions (G.R. Nos. 85594, 85597, and 85621) challenging the Sandiganbayan’s orders and jurisdiction over the cases.
Issue:
- Whether the Sandiganbayan had jurisdiction over the injunction suits filed by Jose L. Africa, Manuel Nieto, and Rafael Valdez against the PCGG and its nominees.
- Whether the actions for injunction constituted suits against the State, which would be barred by the doctrine of state immunity.
- Whether the issues raised in the injunction suits were barred by res judicata due to prior judgments in related cases.
- Whether the Sandiganbayan acted with grave abuse of discretion in deferring the resolution of motions to dismiss in Civil Case No. 0048.
- Whether the Sandiganbayan’s issuance of subpoenas duces tecum and ad testificandum was valid.
Ruling:
Jurisdiction of the Sandiganbayan: The Supreme Court held that the Sandiganbayan had exclusive and original jurisdiction over the injunction suits because they arose from the sequestration of ETPI, a matter related to the recovery of ill-gotten wealth under Executive Order No. 14.
State Immunity: The Court ruled that the doctrine of state immunity did not apply because the complaints sought redress for alleged illegal acts by individual defendants in their personal capacities, not against the State.
Res Judicata: The Court found that the doctrine of res judicata did not apply because the prior judgment in G.R. No. 82188 did not resolve the merits of the factual issues raised in the current cases.
Grave Abuse of Discretion: The Court held that the Sandiganbayan’s deferment of the resolution of motions to dismiss in Civil Case No. 0048 was tainted with grave abuse of discretion since the motions raised jurisdictional issues that could be resolved without a trial on the merits.
Validity of Subpoenas: The Court upheld the Sandiganbayan’s issuance of the subpoenas, citing the right of stockholders to inspect corporate records under Section 74 of the Corporation Code.
Ratio:
- Exclusive Jurisdiction: The Sandiganbayan has exclusive jurisdiction over all cases and incidents related to the recovery of ill-gotten wealth, including injunction suits arising from sequestration.
- State Immunity: The doctrine of state immunity does not bar suits against individual government officials acting in their personal capacities.
- Res Judicata: For res judicata to apply, the prior judgment must be on the merits of the case, which was not the case here.
- Multiple Suits: Factual issues raised in these cases are best resolved in the main case (Civil Case No. 0009) to avoid multiplicity of suits.
- Stockholder Rights: Stockholders have the right to inspect corporate records, and this right is not abrogated by sequestration.