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...

Facts:

Sequestration and Corporate Changes

• The Presidential Commission on Good Government (PCGG) sequestered Eastern Telecommunications Philippines, Inc. (ETPI) on March 14, 1986.
• Shortly thereafter, in May 1986, the sequestration order was partially lifted for Cable and Wireless, Ltd.’s 40% Class B shares while 60% Class A shares remained sequestered.
• On July 22, 1987, the PCGG filed an action for reconveyance, reversion, accounting, and restitution of the alleged ill-gotten ETPI shares, docketed as Civil Case No. 0009 in Sandiganbayan.

Election and Board Restructuring

• A special stockholders meeting was convened on January 29, 1988 pursuant to a PCGG resolution (originally scheduled for January 4, 1988).
• During the meeting, nominees of both the PCGG and foreign investors were elected as members of the ETPI board.
• Subsequently, an organizational meeting was held where Eduardo M. Villanueva as PCGG nominee was elected president and general manager, and additional officers were similarly installed.
• These actions led to contentious proceedings regarding the validity and legality of the board’s composition and the method of election.

Litigation by Affected Parties

• Victor Africa, claiming to be an employee holding multiple positions at ETPI, directly filed an original petition with the Supreme Court (G.R. No. 83831) for a writ of injunction to stop the PCGG and its nominees from allegedly ousting him from his posts.
• Africa contended that the reasons for his removal (redundancy, fund conservation, and loss of confidence) were arbitrary and intended to harass him to prevent further judicial inquiry into the PCGG-sponsored board actions.
• He also sought relief by accusing a PCGG official of contempt of court when alleged actions led to his forcible removal from the office.

Parallel and Consolidated Proceedings in Sandiganbayan

• Separate injunction and damages actions were instituted in the Sandiganbayan by stockholders—Jose L. Africa, Manuel Nieto, Rafael Valdez, and others—in Civil Cases Nos. 0048 and 0050.
• These suits challenged the legality of the PCGG’s nomination/election of directors and officers, alleging that the actions were taken without due process and with the improper use of sequestered shares.
• The defendants (including PCGG nominees and representatives of foreign investors) filed motions to dismiss on several grounds including lack of jurisdiction, the improper nature of the suit (akin to quo warranto), and claims of res judicata based on a prior Supreme Court decision (G.R. No. 82188).

Subpoenas and Further Procedural Developments

• The Sandiganbayan issued subpoenas duces tecum and ad testificandum for company records such as the stock and transfer books, stock certificates, and board/stockholders meeting minutes covering the period from January 29, 1988, onward.
• The PCGG and its nominee (Ramon Desuasido) moved to quash the subpoenas; however, the motion was denied.
• A series of postponements, motions to defer, motions to dismiss, and subsequent temporary restraining orders ensued amid complex litigation.

Consolidation and Referrals

• The four related cases (G.R. Nos. 83831, 85594, 85597, and 85621) were consolidated by the Supreme Court pursuant to a resolution dated November 22, 1988 due to their common nexus involving the sequestration of ETPI and the contested board elections.
• The Supreme Court identified overlapping issues and the need for a uniform resolution regarding the procedural and substantive challenges raised by the parties.

Issue:

Jurisdictional Authority

• Whether the Sandiganbayan has exclusive and original jurisdiction over actions involving the PCGG, its nominees, and incidents arising from the setting of the sequestration of ETPI.
• Whether the motions to dismiss based on lack of jurisdiction should be resolved prior to the merits or be deferred.

Nature of the Injunction Actions

• Whether the injunction suits filed by private parties (stockholders and a corporate officer) against the PCGG’s actions constitute proper special civil actions or instead amount to a suit against the State (thus invoking state immunity).
• Whether including a claim for damages alongside an injunction transforms the nature of the action and affects the applicable rules regarding state immunity.

Res Judicata and Prior Judgment

• Whether the doctrine of res judicata bars the current actions on the ground that the underlying issues were already raised and passed upon in earlier cases (notably, G.R. No. 82188).
• Whether there exists identity among parties, subject matter, and causes of action between the prior judgment and the present cases.

Procedural Posture and Evidence Issues

• Whether the issuance of subpoenas for corporate records by the Sandiganbayan was proper, and if such measures interfered with the rights of the PCGG.
• Whether the deferment of motions to dismiss in the pending injunction proceedings constitutes a grave abuse of discretion.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)