Case Digest (G.R. No. 169914) Core Legal Reasoning Model
Facts:
This case involves petitioner Jesus P. Disini and respondents The Honorable Sandiganbayan and the Republic of the Philippines, represented by the Presidential Commission on Good Government (PCGG). In 1989, the PCGG, on behalf of the Republic, sought Disini's testimony in its cases against Westinghouse Electric Corporation before the United States District Court of New Jersey and before the International Chamber of Commerce Court of Arbitration. Disini was an executive in companies of his second cousin, Herminio T. Disini, from 1971 to 1984. The Republic believed that the contract for the construction of the Bataan Nuclear Power Plant, brokered by one of Herminio's companies, involved irregularities.
On February 16, 1989, Disini and the Republic entered into an Immunity Agreement whereby Disini agreed to testify in the two specified cases and provide all necessary documents and affidavits. In exchange, the Republic guaranteed that apart from these two cases, it would not
Case Digest (G.R. No. 169914) Expanded Legal Reasoning Model
Facts:
- Background of the case
- In 1989, the Republic of the Philippines, through the Presidential Commission on Good Government (PCGG), sought the testimony of Jesus P. Disini in two legal actions involving Westinghouse Electric Corporation:
- A civil case pending before the United States District Court for the District of New Jersey.
- Arbitration proceedings before the International Chamber of Commerce Court of Arbitration.
- Disini was employed by his second cousin, Herminio T. Disini, as an executive in Herminio’s companies from 1971 to 1984.
- The Republic suspected irregularities in the Westinghouse contract for the construction of the Bataan Nuclear Power Plant, which was brokered by one of Herminio’s companies.
- Immunity Agreement executed on February 16, 1989
- The Republic and Disini entered into a comprehensive Immunity Agreement where Disini committed to:
- Testify truthfully in the identified cases.
- Provide affidavits, information, documents, and cooperate with the Republic’s attorneys.
- The Republic guaranteed that Disini would not be compelled to testify in any other proceeding, domestic or foreign, against Herminio.
- Key provisions:
- Disini agreed to testify in the specific Westinghouse cases only.
- The Republic would not prosecute Disini criminally, civilly, or administratively related to:
- The Republic would not use information obtained from Disini against him.
- Paragraph 3 barred the Republic from compelling Disini to testify against Herminio in any related matters but did not affect Disini’s obligation to provide truthful information or testimony in the specified cases.
- Subsequent events
- Disini complied with his obligations under the Immunity Agreement.
- On February 27, 2007, the Republic filed an action before the Sandiganbayan against Herminio. The Sandiganbayan issued subpoenas to Disini to testify and produce documents.
- Disini filed motions to quash the subpoenas, invoking the Immunity Agreement. The Sandiganbayan denied these motions and reaffirmed its authority to compel Disini’s testimony.
- On July 19, 2007, the PCGG unilaterally revoked and nullified the Immunity Agreement insofar as it prohibited Disini from testifying against Herminio.
- Disini sought relief from the Supreme Court, challenging the revocation and the Sandiganbayan’s refusal to quash the subpoena.
Issues:
- Whether the PCGG acted within its authority in revoking and nullifying the Immunity Agreement between the Republic and Disini.
- Whether the Sandiganbayan gravely abused its discretion in denying Disini’s motion to quash the subpoena ordering him to testify against Herminio.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)