Case Digest (G.R. No. 92422)
Facts:
The case involves American Inter-Fashion Corporation (AIFC) as the petitioner and the Office of the President, Garments and Textile Export Board (GTEB), and Glorious Sun Fashion Garments Manufacturing Co. (Philippines), Inc. as respondents. The events leading to this case began on April 24, 1984, when the GTEB found Glorious Sun guilty of misdeclaration of imported raw materials, which resulted in the cancellation of its export quotas. The quotas were subsequently allocated to two newly-formed corporations, AIFC and De Soleil Apparel Manufacturing Corporation, both of which were joint ventures involving Hong Kong investors and associates of the Marcos family.
Following the GTEB's decision, the Office of the President intervened, setting aside the GTEB ruling and remanding the case for further hearings to ensure due process for both parties. AIFC contended that the GTEB's decision was res judicata, asserting that Glorious Sun had been given ample opportunity to defe...
Case Digest (G.R. No. 92422)
Facts:
Background of the Case:
- The case involves the cancellation of export quotas allocated to Glorious Sun Fashion Garments Manufacturing Co. (Phils.), Inc. (Glorious Sun) by the Garments and Textile Export Board (GTEB) in 1984. The GTEB found Glorious Sun guilty of misdeclaration of imported raw materials, leading to dollar salting abroad. As a result, Glorious Sun's export quotas were canceled and reallocated to two newly formed corporations, De Soleil Apparel Manufacturing Corporation (De Soleil) and American Inter-Fashion Corporation (AIFC).
Creation of AIFC and De Soleil:
- AIFC and De Soleil were joint ventures between Hong Kong investors and majority stockholders of Glorious Sun, allegedly involving a member of the Marcos family and a crony of President Marcos.
Office of the President's Intervention:
- The Office of the President set aside the GTEB's 1984 decision and remanded the case for further hearings, citing a lack of due process. Glorious Sun was given the opportunity to appeal the GTEB's decision, leading to the current petition.
Sequestration Issues:
- Glorious Sun was never sequestered, while AIFC's sequestration was lifted. De Soleil remains sequestered but is not a party to this petition.
Procedural History:
- Glorious Sun initially filed a petition with the Supreme Court (G.R. No. 67180) challenging the GTEB's 1984 decision but later withdrew it due to alleged coercion by then-Minister Roberto Ongpin. In 1986, Glorious Sun filed a petition with the GTEB for the restitution of its export quotas, which was denied. The Office of the President later ruled in favor of Glorious Sun, ordering the GTEB to reopen the case.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Jurisdiction of the Sandiganbayan:
- The Sandiganbayan's jurisdiction is limited to cases involving the recovery of ill-gotten wealth acquired by the Marcos family and their associates. The cancellation of Glorious Sun's export quotas in 1984 is a separate administrative matter and does not fall under the Sandiganbayan's jurisdiction.
Res Judicata:
- For a judgment to constitute res judicata, it must be a final judgment on the merits. The dismissal of Glorious Sun's earlier petition was based on a technical matter (withdrawal of the petition) and not on the merits of the case. Therefore, it does not bar the current petition.
Due Process:
- Due process requires that a party be given a fair opportunity to present its case and confront the evidence against it. The GTEB's failure to disclose evidence used against Glorious Sun in 1984 violated its right to due process. The subsequent disclosure of evidence in 1987 did not cure this defect.
Administrative Review:
- The Office of the President has the authority to review administrative decisions, such as the GTEB's 1984 decision, to ensure that due process was observed. The Office of the President did not commit grave abuse of discretion in remanding the case for further proceedings.
Conclusion:
The Supreme Court granted the motion for reconsideration and dismissed the petition. The decision and resolution of the Office of the President were affirmed, and the case was remanded to the GTEB for further proceedings to ensure that Glorious Sun's right to due process is upheld.