Title
BLEMP Commercial of the Philippines, Inc. vs. The Hon. Sandiganbayan 1st Division, Presidential Commission on Good Government, Ortigas and Company Limited Partnership, Ricardo C. Silverio, and Mid-Pasig Land Development Corporation
Case
G.R. No. 199031
Decision Date
Oct 10, 2022
A dispute over the validity of property sale contracts allegedly made under intimidation by Marcos spurred litigations involving ownership claims, government seizures, motions for injunction, intervention, and summary judgment. The Supreme Court affirmed the Sandiganbayan ruling dismissing Ortigas's annulment claim, denied BLEMP's intervention, upheld PCGG's ownership and disposal rights over the properties.

Case Digest (G.R. No. 211362)
Expanded Legal Reasoning Model

Facts:

  • Parties and Litigation Background
    • Seven petitions were consolidated and filed before the Supreme Court, assailing nine resolutions and one decision of the Sandiganbayan related to the ownership and disposition of certain properties.
    • The parties involved include BLEMP Commercial of the Philippines, Inc. (BLEMP), Ortigas & Company Limited Partnership (Ortigas), the Presidential Commission on Good Government (PCGG), Ortigas & Company Limited Partnership, Ricardo C. Silverio (substituted by his surviving spouse Lorna Cillan-Silverio), and Mid-Pasig Land Development Corporation (Mid-Pasig).
    • Ortigas is a real estate corporation owning 180 hectares of land spanning Pasig City, San Juan City, Mandaluyong City, Rizal, and Quezon City.
  • Historical and Transactional Context
    • In 1968, the Marcos Spouses expressed interest in a prime 16-hectare portion of Ortigas’s estate, seeking its use as a residence, museum, and for investment.
    • Ortigas's Board initially rejected the proposal but allegedly acceded after President Ferdinand E. Marcos threatened to use his powers to harass Ortigas and its officers.
    • A Deed of Conditional Sale was executed selling the 16-hectare property at P40.00 per square meter to Maharlika Estate Corporation, Marcos's nominee, later transferred to Mid-Pasig.
    • A final Deed of Sale and Transfer Certificates of Title were issued in favor of Mid-Pasig.
    • A Supplementary Agreement was executed later involving an additional 2.4-hectare strip allegedly given on the same pretext.
  • Post-Marcos Regime Actions
    • After the 1986 EDSA Revolution, Jose Y. Campos, president of Anchor Estate and Mid-Pasig, voluntarily surrendered titles and possession of these properties to the government under PCGG control.
    • Ortigas sought recovery, filing complaints to annul the sale claiming the contracts were void due to threats and intimidation by Marcos.
    • Silverio, representing Anchor Estate, also contested the ownership and transfers involving Mid-Pasig.
  • Motions and Trial Court Proceedings
    • BLEMP moved to intervene, claiming ownership through purchases from Mid-Pasig.
    • Ortigas applied for injunction and receivership to prevent PCGG and Mid-Pasig from leasing or disposing of the properties.
    • The Sandiganbayan denied BLEMP’s intervention, Ortigas’s injunction and receivership motions, citing lack of clear ownership, absence of irreparable injury, and sufficient protection through lis pendens.
    • PCGG moved for summary judgment; the Sandiganbayan partially granted motion dismissing Silverio’s complaint but denied it with respect to Ortigas’s complaint pending trial.
    • Evidence and testimonies, including letters and affidavits, were considered; admission of documents was given judicial admission status but Atty. Francisco Ortigas’s affidavit was excluded due to hearsay and lack of cross-examination.
  • Recent Developments
    • PCGG attempted to dispose of the properties through bidding, which failed due to no bid submission.
    • Ortigas’s Complaint for annulment and recovery was dismissed by the Sandiganbayan due to insufficient evidence.
    • Seven petitions filed before the Supreme Court assailed the Sandiganbayan’s rulings.

Issues:

  • Whether the Sandiganbayan gravely abused its discretion in denying BLEMP's Motion for Leave to Intervene.
  • Whether the Sandiganbayan gravely abused its discretion in denying Ortigas’s application for injunction and receivership.
  • Whether the Sandiganbayan gravely abused its discretion in denying the PCGG’s Motion for Summary Judgment regarding Ortigas’s Complaint, and in granting summary judgment with respect to Silverio’s Complaint.
  • Whether the Sandiganbayan gravely abused its discretion in dismissing Ortigas's Complaint for annulment/declaration of nullity and recovery of possession.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.