Case Digest (G.R. No. L-6408) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Cojuangco v. Sandiganbayan, petitioner Eduardo M. Cojuangco, Jr. challenged Civil Case Nos. 0033-B, ‑C, ‑D, ‑E, ‑G, and ‑H, all subdivisions of PCGG’s Civil Case No. 0033 filed on July 31, 1987 before the Sandiganbayan for recovery of alleged ill-gotten wealth under E.O. Nos. 1, 2, and 14. The complaint was amended thrice, then subdivided in 1999 into eight distinct cases, six of which remain pending against petitioner. Pre-trial hearings in several cases were suspended or terminated between 2000 and 2003, and motions for partial summary judgment, motions for judgment on the pleadings, and motions to dismiss were filed by both parties over the next two decades. Despite repeated denials of those motions, no pre-trial orders were issued to set trial dates. Petitioner repeatedly invoked his rights to due process and speedy disposition of cases, but by July 18, 2019, more than 32 years after filing, trial had not commenced. He then sought a writ of prohibition under Rule 65, argu Case Digest (G.R. No. L-6408) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Creation of PCGG and Vesting of Jurisdiction
- February 28, 1986 – E.O. No. 1 creates PCGG to recover ill-gotten wealth of Ferdinand E. Marcos, his relatives, subordinates, and associates.
- March 12, 1986 – E.O. No. 2 further tasks PCGG to recover assets illegally acquired by Marcos and Imelda Marcos, their close circles and nominees.
- May 7, 1986 (as amended Aug. 18, 1986) – E.O. No. 14 vests exclusive original jurisdiction over “ill-gotten wealth” cases in the Sandiganbayan.
- Republic Acts Nos. 7975 (1995) and 8249 (1997) reaffirm Sandiganbayan’s jurisdiction and adoption of Supreme Court Rules of Court.
- Civil Case No. 0033 Against Cojuangco
- July 31, 1987 – PCGG, in the name of the Republic of the Philippines, files Civil Case No. 0033 for recovery of alleged ill-gotten wealth against Eduardo M. Cojuangco, Jr. and others; complaint amended thrice, latest in August 1991.
- March 24, 1999 – Sandiganbayan subdivides Civil Case No. 0033 into eight separate civil complaints (0033-A to 0033-H). Petitioner contends 0033-A and ‑F resolved; six subject cases remain: B, C, D, E, G, H.
- Pre-trial, Motions, and Delay
- 1995–2000 – PCGG files subdivided complaints (early 1995); Cojuangco files answers (June–July 1999); both parties file pre-trial briefs (2000). Pre-trial hearings:
- 0033-B/E/H/G – pre-trial suspended for PCGG’s motions for partial summary judgment or judgment on the pleadings.
- 0033-C/D/E – pre-trial terminated (2000–2003).
- 2002–2006 – PCGG files motions for partial summary judgment or judgment on the pleadings in all subject cases except 0033-H; Sandiganbayan denies motions (2006–2016).
- 2011–2017 – PCGG files motions for reconsideration of denial; Sandiganbayan denies all (2012–2017).
- 2013–2015 – Cojuangco files motions to dismiss for violation of his rights to due process and speedy disposition; Sandiganbayan denies five (2013–2017); 0033-C motion remains unresolved.
- February 2, 2018 – Petitioner moves to include subject cases in court calendar; Sandiganbayan does not act.
- Petition for Prohibition
- July 18, 2019 – Cojuangco files Petition for Prohibition under Rule 65 to enjoin Sandiganbayan from further proceedings in Cases 0033-B, ‑C, ‑D, ‑E, ‑G, ‑H and to dismiss them for more than 32 years of inaction violating his constitutional rights to due process and speedy disposition of cases.
- PCGG’s procedural objections – asserts petition is a belated attack on final interlocutory orders, alleges forum shopping, and contends there was no unjustified delay.
- Petitioner’s reply – interlocutory orders are modifiable, petition challenges collective inaction and jurisdictional excess, not specific resolutions; rights are paramount.
Issues:
- Procedural
- Whether the petition for prohibition improperly seeks to amend or modify interlocutory Sandiganbayan resolutions and thus violates immutability of judgment or is barred by forum shopping.
- Whether prohibition is a plain, speedy, and adequate remedy as required by Rule 65.
- Substantive
- Whether Sandiganbayan acted without or in excess of jurisdiction or with grave abuse of discretion by allowing the subject cases to languish for decades without commencing trial.
- Whether petitioner’s constitutional rights to due process and speedy disposition of cases were violated, justifying dismissal of the cases.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)