G.R. No. 183278 - Cojuangco vs. Sandiganbayan

On July 16, 1987, the Republic of the Philippines (Republic) filed a "Complaint for Reconveyance, Reversion, Accounting, Restitution and Damages" before the Sandiganbayan, docketed as Civil Case 0002, seeking recovery of alleged ill-gotten wealth from the late President Ferdinand Marcos and former First Lady Imelda Marcos, including about 2.4 million shares of stock in the Philippine Long Distance Telephone Company (PLDT).
The complaint was later amended to implead petitioners Imelda O. Cojuangco, Prime Holdings, Inc., and the Estate of Ramon U. Cojuangco. It alleged that the Marcoses’ ill-gotten wealth included shares in PLDT covered by shares of stock in the Philippine Telecommunications Investment Corporation (PTIC), registered under Prime Holdings, Inc. (Prime Holdings).

The Sandiganbayan initially dismissed the complaint concerning the PLDT shares, leading the Republic to appeal before the Supreme Court. The appeal was docketed as G.R. No. 153459 and consolidated with related cases (G.R. Nos. 149802, 150320, 150367).
On January 20, 2006, the Supreme Court ruled in favor of the Republic, declaring it the owner of 111,415 PTIC shares registered in the name of Prime Holdings. The dispositive portion instructed reconveyance of those shares to the Republic. The decision became final and executory on October 26, 2006.

On November 20, 2006, the Republic filed a Motion for Issuance of Writ of Execution before the Sandiganbayan to enforce the Supreme Court’s decision, praying for:

Cancellation of the 111,415 shares/certificates of stock registered under Prime Holdings.
Annotation of ownership change in PTIC’s Stock and Transfer Book.
Accounting for all cash and stock dividends declared or issued by PLDT in favor of PTIC from 1986 onwards, including compounded interests.

By a December 14, 2006 Resolution, the Sandiganbayan granted the motion as to reconveyance but denied the accounting for dividends.
Upon motion for reconsideration, the Sandiganbayan issued a November 7, 2007 Resolution directing PTIC to deliver the cash and stock dividends pertaining to the 111,415 shares, including compounded interests, reasoning that such fruits belonged to the Republic as the owner of the shares.

Petitioners moved to reconsider, contending that the Supreme Court decision did not discuss dividends and interests and thus did not authorize their recovery.
Through a June 13, 2008 Resolution, the Sandiganbayan partially granted the motion by ordering payment of legal (but not compounded) interest, and issued a writ of execution accordingly, which was challenged via this petition for certiorari.

Whether the Sandiganbayan gravely abused its discretion in ordering the accounting, delivery, and remittance of stock, cash, and property dividends pertaining to the 111,415 PTIC shares, despite the Supreme Court’s decision in G.R. No. 153459 not expressly discussing the dividends and interests.
Whether the Republic, having transferred the 111,415 shares to a third party (Metro Pacific Assets Holdings, Inc.), is entitled to the dividends, interests, and earnings accruing from those shares.