Case Digest (G.R. No. 137172) Core Legal Reasoning Model
Facts:
The consolidated cases arise from petitions involving Palm Avenue Holding Co., Inc. and Palm Avenue Realty and Development Corporation (collectively, the Palm Companies) against the Presidential Commission on Good Government (PCGG) and the Sandiganbayan. On October 27, 1986, the PCGG issued a writ of sequestration covering the Palm Companies’ assets, including over 16 million Benguet Corporation shares registered in their name. This was premised on allegations that the Palm Companies held such shares for Benjamin "Kokoya" Romualdez, a crony of former President Ferdinand Marcos, identified as the beneficial owner. The PCGG filed a complaint with the Sandiganbayan docketed as Civil Case No. 0035 against Romualdez but initially did not implead the Palm Companies as defendants. In 1989, the Sandiganbayan ordered the Palm Companies impleaded, an order later affirmed by the Supreme Court in 1991.
The Palm Companies challenged the writ of sequestration, filing a motion to li
Case Digest (G.R. No. 137172) Expanded Legal Reasoning Model
Facts:
- Background and Parties
- The case involves Palm Avenue Holding Co., Inc. and Palm Avenue Realty and Development Corporation (collectively, "Palm Companies") and the Republic of the Philippines, represented by the Presidential Commission on Good Government (PCGG).
- The Palm Companies are owners of 16,237,339 shares of Benguet Corporation, allegedly held beneficially by Benjamin "Kokoya" Romualdez, identified as a crony of former President Ferdinand Marcos.
- The Republic, through the PCGG, sequestered all assets, properties, records, and documents of the Palm Companies by a writ of sequestration dated October 27, 1986.
- Procedural History
- The PCGG filed a complaint in Sandiganbayan as Civil Case No. 0035 against Benjamin Romualdez but initially did not implead the Palm Companies as defendants.
- On June 16, 1989, the Sandiganbayan ordered the Palm Companies to be impleaded, affirmed by the Supreme Court in G.R. No. 90667 on November 5, 1991.
- The Republic filed an amended complaint on January 17, 1997, naming the Palm Companies as defendants; the graft court admitted it on October 15, 2001.
- The Palm Companies moved to lift the writ of sequestration on February 11, 1997, but the Sandiganbayan denied the motion on January 10, 2003, and again on reconsideration on June 14, 2006.
- The Palm Companies filed a Petition for Certiorari (G.R. No. 173082) challenging these resolutions.
- Subsequently, on September 22, 2006, the Palm Companies filed a motion to release sequestered funds. The Sandiganbayan, in a resolution dated January 18, 2007, granted this motion with specific directions.
- The Palm Companies filed a Motion for Bill of Particulars; the Republic submitted its bill on December 21, 2007. The Palm Companies then moved to dismiss the complaint, contending the bill was insufficient.
- The Sandiganbayan granted the motion to dismiss on September 29, 2008, a decision affirmed by the Supreme Court on January 20, 2010 (G.R. No. 189771).
- The Palm Companies also filed a motion to order payment of interest on sequestered funds, granted on October 28, 2009.
- On May 14, 2010, the Palm Companies moved to order the PCGG to release their shares and funds; the Sandiganbayan granted this on October 21, 2010.
- The Republic filed a Petition for Certiorari and Prohibition (G.R. No. 195795) challenging the Sandiganbayan’s grant of the motion to release shares and funds and its resolution dismissing the complaint.
Issues:
- Whether the Sandiganbayan gravely abused its discretion and exceeded its jurisdiction in denying the Palm Companies’ motion to lift the writ of sequestration despite the constitutional requirement under Section 26, Article XVIII of the 1987 Constitution that sequestration orders be lifted automatically if the judicial action is not commenced within six months; and whether the failure of the Republic to timely implead the Palm Companies barred the continued sequestration of their assets.
- Whether the Sandiganbayan gravely abused its discretion in granting the motion of the Palm Companies to release their shares and funds in the custody of PCGG despite the pending case.
- Whether the complaint filed by the Republic against the Palm Companies sufficiently states a cause of action; and whether the dismissal of the complaint as to the Palm Companies was proper due to failure to file a proper bill of particulars.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)