Case Digest (G.R. No. L-14279)
Facts:
Metropolitan Bank and Trust Company v. Hon. Edilberto G. Sandoval, et al., G.R. No. 169677, February 18, 2013, Supreme Court First Division, Bersamin, J., writing for the Court.In 1987 the Republic of the Philippines filed a complaint in the Sandiganbayan (Civil Case No. 0004) for reversion, reconveyance, restitution, accounting and damages seeking recovery of alleged ill-gotten wealth of the Marcoses and their associates. Among the properties listed were two parcels in Tandang Sora, Quezon City, originally titled in the names of Spouses Andres V. Genito, Jr. and Ludivina L. Genito (TCT Nos. 266423 and 266588). The Republic later moved (Feb. 5, 2001) to amend its complaint to implead Asian Bank Corporation as an additional defendant; Asian Bank claimed record titles (TCT Nos. N-201383 and N-201384) and possession by virtue of a writ of possession from the Regional Trial Court in Quezon City.
When the Republic was about to conclude its presentation of evidence against the original defendants, it moved for a separate trial as to Asian Bank. Asian Bank opposed immediate separation, asking to be afforded the opportunity to test and challenge the evidence already presented before being made a party; it argued that its right to due process would be prejudiced if tried separately and that the Sandiganbayan lacked jurisdiction to decide Asian Bank’s ownership interest. The Republic replied that the cause of action against Asian Bank was distinct — limited to whether Asian Bank had actual or constructive knowledge that the properties were subject of the recovery suit — and thus separate trial was proper.
On June 25, 2004 the Sandiganbayan issued a resolution granting the Republic’s motion for separate trial (finding the claim against Asian Bank distinct and incidental), and on July 13, 2005 it denied Asian Bank’s motion for reconsideration. Thereafter Metropolitan Bank and Trust Company (Metrobank), as successor-in-interest to Asian Bank and transferee of the properties, filed a special civil action for certiorari in the Supreme Court seeking to annul the two Sandiganbayan resolutions granting separate trial and to assert that the Sandiganbayan lacked jurisdiction over the claim against Asian Bank.
The Sandiganbayan defended its rulings, and the Republic argued that separate trial...(Subscriber-Only)
Issues:
- Did the Sandiganbayan commit grave abuse of discretion in granting the Republic’s motion for a separate trial as to Asian Bank (Metrobank)?
- Was the Sandiganbayan correct in holding that the only issue as to Asian Bank was whether it acquired the properties in bad faith (i.e., that this issue was distinct and separable from the main action)?
- Did the Sandiganbayan have original and exclusive jurisdiction over the Republic’s...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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