Case Digest (G.R. No. 87710)
Facts:
Roberto S. Benedicto v. Board of Administrators of Television Stations RPN, BBC and IBC, G.R. No. 87710; Teofisto T. Guingona, Jr. v. Presidential Commission on Good Government, G.R. No. 96087, March 31, 1992, Supreme Court En Banc, Grino-Aquino, J., writing for the Court.After the February 1986 Revolution, the broadcast complex known as Broadcast City (Inter-Continental Broadcasting Corporation IBC‑13, Radio Philippines Network RPN‑9, Banahaw Broadcasting Corporation BBC‑2) was effectively abandoned. The Presidential Commission on Good Government (PCGG) recommended sequestration in the interest of national security and to clarify ownership; following that recommendation the Ministry of National Defense asked the Ministry of Information to manage the facilities, and President Corazon C. Aquino issued Executive Order No. 11 (April 8, 1986) creating a Board of Administrators to "manage and operate the business and affairs of Broadcast City," with powers modelled on corporate boards and trustees and a term coterminous with PCGG investigations.
Pursuant to EO No. 11 the Board of Administrators was appointed on April 11, 1986. Meanwhile, petitioner Roberto S. Benedicto filed a case to annul the sequestration and recover management of Broadcast City (G.R. No. 74974), now pending before the Sandiganbayan. On December 18, 1986, Benedicto and the PCGG allegedly agreed to reorganize the corporations’ Boards of Directors so that two‑thirds of each reorganized board would be PCGG nominees and one‑third Benedicto nominees; reorganized boards were thereafter elected. The Board of Administrators refused to relinquish management, prompting Benedicto to file a petition for prohibition and mandamus (with prayer for injunctive relief) in the Supreme Court — G.R. No. 87710 — seeking to compel surrender of control to the reorganized boards.
Separately, on June 30, 1987 the PCGG filed Civil Case No. 0034 in the Sandiganbayan to recover alleged ill‑gotten wealth from Benedicto and others. On November 3, 1990 the PCGG, through its chairman, executed a Compromise Agreement with Benedicto ceding to him a substantial part of the disputed assets and granting immunity; the agreement was submitted to the Sandiganbayan on November 25, 1990. Senator Teofisto T. Guingona, Jr. filed a petition for certiorari and prohibition (with prayer for preliminary injunction) in G.R. No. 96087 to invalidate the Benedicto compromise on multiple grounds: that the PCGG lacked authority to cede ill‑gotten assets or grant the claimed immunity; that the agreement violated the conditions of Executive Order No. 14 (as amended) regarding immunity and full disclosure; that prior congressional approval was required under Sec. 20, Ch. 4, Subtitle B, Title I, Book V of the Revised Administrative Code (E.O. No. 292) for settling government claims in excess of P100,000; and that the PCGG had abused its discret...(Pro-only)
Issues:
- Did the Board of Administrators act without or in excess of jurisdiction in refusing to surrender management and control of Broadcast City to the reorganized Boards of Directors, thereby warranting issuance of prohibition and mandamus?
- Did the PCGG act without or in excess of its authority in entering into and submitting for court approval the Compromise Agreement with Benedicto — including granting immunity and ceding alleged ill‑gotten assets — and did such compromise require prior congressional approval or compliance with t...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)