Case Digest (G.R. No. 92422)
Facts:
American Inter-Fashion Corporation v. Office of the President, Garments & Textile Export Board & Glorious Sun Fashion Garments Manufacturing Co. (Phils.), Inc., G.R. No. 92422, May 23, 1991, the Supreme Court En Banc, Gutierrez, Jr., J., writing for the Court.Petitioner American Inter-Fashion Corporation (AIFC) sought relief from the Supreme Court after the Office of the President (OP) issued a decision in OP Case No. 3781 on September 7, 1989, that found irregularities in a 1984 Garments and Textile Export Board (GTEB) decision cancelling export quotas of private respondent Glorious Sun Fashion Garments Manufacturing Co. (Glorious Sun) and remanded OSC Case No. 84-B-1 to GTEB for further proceedings. AIFC, which claimed entitlement to those quotas, opposed the OP decision and filed a motion for reconsideration that was denied on February 20, 1990; AIFC then petitioned this Court.
The controversy began with GTEB's April 27, 1984 decision finding Glorious Sun guilty of misdeclaration/dollar-salting and cancelling its export quotas, quotas later reallocated to two newly formed corporations, De Soleil Apparel Manufacturing Corporation (De Soleil) and AIFC. Glorious Sun filed certiorari and prohibition with this Court as G.R. No. 67180; the Court on June 4, 1984 ordered GTEB to conduct further proceedings, but Glorious Sun manifested its intention to withdraw and on August 20, 1984 the Court granted withdrawal (noting issues had not been joined), the dismissal being recorded on September 10, 1984.
In October 1986 Glorious Sun petitioned GTEB for restitution and alleged that Minister Roberto V. Ongpin had exerted duress and undue influence to transfer its quotas to cronies; GTEB denied restitution on September 4, 1987. Glorious Sun appealed to OP on October 5, 1987; AIFC sought to intervene and opposed the appeal on November 27, 1987. On September 7, 1989 OP ruled for Glorious Sun, finding GTEB's 1984 proceedings irregular and remanding for a genuine hearing. AIFC challenged the OP ruling in the Supreme Court, alleging (1) OP committed grave abuse of discretion in taking cognizance of Glorious Sun's appeal (arguing it amounted to review of a final court judgment and that Glorious Sun had abandoned the appeal), and (2) OP erred in finding denial of due process by GTEB.
During the litigation the record showed that Glorious Sun was never sequestered, AIFC's sequestration had been lifted, and De Soleil (not a party here) remained sequestered. An affidavit of Rodolfo V. Puno dated April 7, 1986, submitted to the PCGG, alleged pressure by Minister Ongpin to find Glorious Sun guilty; GTEB members later disavowed such pressure. GTEB also furnished documents in 1987 that had not been disclosed in 1984—documents that the OP and Glorious Sun ...(Subscriber-Only)
Issues:
- Did the Office of the President commit grave abuse of discretion amounting to lack of jurisdiction in taking cognizance of Glorious Sun’s appeal because (a) it amounted to an administrative review of a final judgment of the courts and (b) Glorious Sun had abandoned its right to appeal?
- Assuming Glorious Sun’s appeal was properly before the Office of the President, did the Office commit grave abuse of discretion in finding that Glorious Sun’s right to procedural ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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