Case Digest (G.R. No. 207619)
Facts:
ECJ and Sons Agricultural Enterprises, Balete Ranch, Inc., Christensen Plantation, Inc., Autonomous Development Corporation, Metroplex Commodities, Inc., Lucena Oil Factory, Inc., and PCY Oil Manufacturing Corporation v. Presidential Commission on Good Government, G.R. No. 207619, April 26, 2021, Supreme Court Third Division, Leonen, J., writing for the Court.Petitioners (collectively, ECJ and Sons, et al.) were record stockholders of United Coconut Planters Bank (UCPB), holding a combined total of 100,085,214 shares. In the wake of the 1986 change in government, the Presidential Commission on Good Government (PCGG) issued a writ of sequestration on May 9, 1986 (Sequestration Order No. 86-0089) against Autonomous Development Corporation’s assets, and on June 6, 1986 (Sequestration Order No. 86-0126) against the UCPB shares registered in the names of ECJ and Sons, et al.
On July 31, 1987 the PCGG filed Civil Case No. 0033 against Eduardo Cojuangco, Jr. and others; that complaint was later divided into eight subcases, including Civil Case No. 0033-A, which concerned UCPB shares allegedly acquired with funds misapplied from the Philippine Coconut Authority (PCA) and coconut levy funds. Although petitioners were not initially impleaded in Civil Case No. 0033-A, the Sandiganbayan later amended pleadings to include certain firms alleged to be Cojuangco fronts.
On January 7, 1991 petitioners filed in the Sandiganbayan a Petition for Certiorari, Prohibition, and Injunction (docketed Civil Case No. 0112) contesting the validity of the two sequestration writs, arguing lack of prima facie evidence and that the PCGG failed to institute judicial action within six months as required by Article XVIII, Section 26 of the 1986 Constitution. On June 9, 2011 the Sandiganbayan granted petitioners’ challenge, declaring the two writs void and lifted, finding absence of prima facie proof and noncompliance with the PCGG Rules (section requiring at least two commissioners to authorize a writ).
Meanwhile, in Civil Case No. 0033-A the Sandiganbayan issued a Partial Summary Judgment on July 11, 2003 ruling that UCPB shares of alleged fronts and nominees forming part of the PCA-paid shares belong to the Republic. The Supreme Court affirmed but modified that Partial Summary Judgment in Cojuangco, Jr. v. Republic (decided November 27, 2012). After those Supreme Court pronouncements, the Sandiganbayan on December 21, 2012 reversed its June 9, 2011 decision and restored the writs of sequestration; it denied reconsideration on June 17, 2013.
Petitioners filed a Petition for Review on Certiorari under Rule 45 on August 8, 2013, arguing (1) they were not bound by COCOFED and Cojuangco, Jr. because they were not impleaded and their shares were not part of the 72.2% characterized in those rulings, (2) a UCPB corporate secretary’s certification indicated their shares came from ...(Subscriber-Only)
Issues:
- May petitioners (corporate stockholders) be bound by the rulings in Republic v. COCOFED and Cojuangco, Jr. v. Republic despite not having been impleaded in those cases?
- Were the nature and ownership of petitioners’ UCPB shares conclusively settled by COCOFED and Cojuangco, Jr.?
- Did the Sandiganbayan correctly restore the writs of seques...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)