Title
Cojuangco, Jr. vs. Sandiganbayan
Case
G.R. No. 247982
Decision Date
Apr 28, 2021
A 32-year delay in resolving ill-gotten wealth cases against Eduardo Cojuangco, Jr. violated his constitutional rights to due process and speedy disposition, leading to case dismissal.

Case Digest (G.R. No. L-6408)
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)

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