Facts:

The case involves Victor Africa as the petitioner against the Honorable Sandiganbayan (Third Division) and private respondents Roman Mabanta, Jr. and Eduardo de los Angeles. The events leading to this case began on March 14, 1986, when the Presidential Commission on Good Government (PCGG) sequestered Eastern Telecommunications Philippines, Inc. (ETPI) under Executive Order No. 1, issued by then President Corazon C. Aquino. The sequestration initially covered 100% of the capital stock of ETPI, but was later lifted for 40% owned by Cable and Wireless, Ltd., leaving 60% owned by individuals including Roberto S. Benedicto and Jose L. Africa, among others, under sequestration. On July 22, 1987, the PCGG filed Civil Case No. 0009 with the Sandiganbayan for the reconveyance and restitution of the alleged ill-gotten shares of ETPI.

On January 29, 1988, during a stockholders meeting, Eduardo M. Villanueva, a PCGG nominee, along with Mabanta and de los Angeles, were elected to the b...

Facts:

Sequestration of ETPI Shares

The Presidential Commission on Good Government (PCGG) sequestered Eastern Telecommunications Philippines, Inc. (ETPI) on 14 March 1986 under Executive Order No. 1. The sequestration initially covered all ETPI shares but was lifted two months later for the 40% Class "B" shares owned by Cable and Wireless, Ltd., a foreign corporation. The remaining 60% Class "A" shares, owned by Roberto S. Benedicto, Jose L. Africa, Polygon Investments & Managers, Inc., Universal Molasses Corporation, and other shares deemed beneficially owned by the late President Ferdinand E. Marcos, remained under sequestration.

Legal Proceedings

On 22 July 1987, the PCGG filed Civil Case No. 0009 with the Sandiganbayan for the reconveyance, reversion, accounting, and restitution of alleged ill-gotten ETPI shares. During the annual stockholders' meeting on 29 January 1988, Eduardo M. Villanueva (PCGG nominee), Roman Mabanta, Jr., and Eduardo de los Angeles (nominees of Cable and Wireless, Ltd.) were elected to the ETPI Board of Directors. This triggered contentious legal proceedings.

Victor Africa's Ouster and Legal Actions

Victor Africa, who held multiple positions at ETPI (Vice-President, General Counsel, Corporate Secretary, and Special Assistant to the Chairman), was ousted from his positions on 30 June 1988. He filed G.R. No. 83831 directly with the Supreme Court, seeking to enjoin his ouster. The Supreme Court referred the case to the Sandiganbayan, which consolidated it with Civil Case No. 0009 and re-docketed it as Civil Case No. 0146. However, the Sandiganbayan dismissed the case on 30 January 1996, ruling it moot and academic due to the consummation of Africa's ouster and lack of jurisdiction over Mabanta and de los Angeles, whose shares were no longer sequestered.

Subsequent Proceedings

Africa's motion for reconsideration was denied on 29 March 1996. He then filed a special civil action for certiorari under Rule 65 of the Rules of Court, challenging the Sandiganbayan's dismissal of Civil Case No. 0146.

Issue:

1. Whether the Sandiganbayan acted with grave abuse of discretion in dismissing Civil Case No. 0146.
2. Whether the petition for injunction was moot and academic.
3. Whether the Sandiganbayan had jurisdiction over private respondents Mabanta and de los Angeles, given their shares were no longer under sequestration.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)