Title
Gaston vs. Republic Planters Bank
Case
G.R. No. 77194
Decision Date
Mar 15, 1988
Sugar producers sought RPB shares funded by stabilization fees; SC ruled fees as public funds, denying private ownership claims.
A

Case Digest (G.R. No. 193657)

Facts:

  • Parties and Representation
    • Petitioners: Sugar producers, planters, and millers, acting individually and as representatives of a larger class.
    • Respondents:
      • Philippine Sugar Commission (PHILSUCOM), later succeeded by the Sugar Regulatory Administration (SRA).
      • Republic Planters Bank (the Bank).
    • Intervenors: Angel H. Severino, Jr., et al., and the National Federation of Sugar Planters (NFSP).
  • Legal and Institutional Background
    • P.D. No. 388 (Feb. 2, 1974) created PHILSUCOM and established a Stabilization Fund, levying P2.00 per picul for five years and P1.00 thereafter.
    • Executive Order No. 18 (May 28, 1986) abolished PHILSUCOM, created SRA, and preserved PHILSUCOM for winding up affairs.
  • Facts Giving Rise to the Petition
    • Stabilization fees (P1.00 per picul) were collected from planters and millers and deposited in PNB as a “Development and Stabilization Fund” “administered in trust” by PHILSUCOM under Sec. 7, P.D. 388.
    • PHILSUCOM used proceeds of the Stabilization Fund to subscribe to 761,416 common shares and 53,005,045 preferred shares of Republic Planters Bank.
    • Petitioners filed for a Writ of Mandamus to compel respondents to transfer the shares from PHILSUCOM’s name to the sugar producers as true beneficial owners.
    • A Trust Agreement (May 28, 1986) between PHILSUCOM and RPB-Trust Department failed for lack of PHILSUCOM Board approval and adverse COA opinion.
    • Respondents PHILSUCOM/SRA contended:
      • No resulting trust arose from Sec. 7, P.D. 388.
      • Fees are government funds under the Government Auditing Code.
      • Transfer of shares would be irregular or illegal.
      • Petition is barred by laches.

Issues:

  • Are the stabilization fees collected under Sec. 7, P.D. 388 trust funds held for the sugar producers, or are they public funds?
  • Do the shares of Republic Planters Bank, purchased with the Stabilization Fund, belong beneficially to PHILSUCOM (and its successor SRA) or to the sugar producers, planters, and millers?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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