Case Digest (G.R. No. 147227)
Facts:
Republic of the Philippines v. Maria Remedios Argana et al., G.R. No. 147227, November 19, 2004, the Supreme Court Second Division, Tinga, J., writing for the Court. The petitioners are members and heirs of the family of the late Maximino A. Argana (through Maria Remedios Argana as administratrix and several heirs and corporate interests); the respondent is the Republic of the Philippines, represented by the Presidential Commission on Good Government (PCGG) and the Office of the Solicitor General (OSG).On July 29, 1987 the Republic filed with the Sandiganbayan a petition for forfeiture of alleged ill‑gotten assets of the late Mayor Argana. The litigation was intermittent: the Sandiganbayan at one point remanded the case to the PCGG for inquiry and the case was reactivated in 1990. The PCGG’s authority to institute preliminary proceedings was litigated up to this Court and upheld in a related 1994 decision. Petitioners filed an answer denying unlawful acquisition and later sought an amicable settlement to avoid protracted litigation.
In mid‑1997 the PCGG En Banc approved an offer of compromise by petitioners. On September 18, 1997 PCGG commissioners executed a Compromise Agreement by which petitioners purportedly ceded 361.9203 hectares (stated to be 75.12% by area of the sequestered parcels) in Pangil and Famy, Laguna, in consideration of dismissal of all pending actions; the remaining 24.88% (120.05392 hectares) was to be retained or otherwise accounted for among heirs, siblings, foreclosed lots and third parties. The PCGG informed the OSG and requested filing of a motion for court approval; the OSG sought clarification about whether the compromise covered all sequestered assets and expressed concerns about values and presidential approval.
President Fidel V. Ramos approved the compromise on May 27, 1998; the OSG filed a Motion to Approve Compromise Agreement on June 4, 1998, to which petitioners assented. The Sandiganbayan issued a Decision on July 31, 1998 approving the compromise. On October 5, 1998 the respondent (through the OSG and PCGG) filed a Motion to Rescind Compromise Agreement and to Set Aside Judgment by Compromise, alleging extrinsic fraud, collusion and that the partition by area (75%/25%) masked a grossly disadvantageous division by value (government obtaining only P3.62M worth whereas petitioners retained assets allegedly worth billions). The Sandiganbayan treated the motion as a petition for relief from judgment under Rule 38 and set it for hearing.
After hearings the Sandiganbayan, in a Resolution dated April 11, 2000, granted the Motion to Rescind and set aside its July 31, 1998 Decision; it found extrinsic fraud and connivance by certain PCGG officials in concealing assessed/market values and characterizing the compromise by area so as to appear to conform to the PCGG’s customary 75%/25% mode. Petitioners filed motions for reconsideration and for v...(Subscriber-Only)
Issues:
- Is a petition for certiorari the proper remedy to assail the Sandiganbayan’s order setting the case for further proceedings after the annulment of a judgment rendered pursuant to a compromise?
- Did the OSG and the PCGG lawyers have authority to file the Motion to Rescind on behalf of the Republic?
- Did the Motion to Rescind, treated as a petition for relief under Rule 38, comply with the requirements of Section 3 of Rule 38 of the 1997 Rules of Civil Procedure?
- Did the Sandiganbayan commit grave abuse of discretion in granting the Motion to Rescind and setting aside its July 31, 1998 Decision approving the compromise?
- Should the members of the Sandiganbayan’s Third Division have voluntarily inh...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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