Case Digest (G.R. No. 192302)
Facts:
Republic of the Philippines, represented by the Anti‑Money Laundering Council v. Rafael A. Manalo, Grace M. Oliva, and Freida Z. Rivera‑Yap, G.R. No. 192302, June 04, 2014, the Supreme Court Second Division, Perlas‑Bernabe, J., writing for the Court.Petitioner Republic of the Philippines, through the Anti‑Money Laundering Council (AMLC), filed two civil forfeiture complaints in the Regional Trial Court (RTC) of Manila: Civil Case No. 03‑107308 (filed July 18, 2003, titled Republic v. R.A.B. Realty, Inc., et al.) and Civil Case No. 03‑107325 (filed July 21, 2003, titled Republic v. Ariola, Jr., et al.). The complaints sought forfeiture of deposits and government securities allegedly traceable to unlawful activity (fraud under the Securities Regulation Code, R.A. No. 8799) and offenses under the Anti‑Money Laundering Act of 2001 (R.A. No. 9160).
On September 25 and 27, 2006, respondents Rafael A. Manalo, Grace M. Oliva, and Freida Z. Rivera‑Yap filed identical Motions for Leave to Intervene and Admit Attached Answer‑in‑Intervention in the two civil forfeiture cases, claiming a legal interest in the bank accounts as assignees of properties of Spouses Saturnino and Rosario Baladjay pursuant to an involuntary insolvency proceeding (Spec. Proc. Case No. 03‑026) pending before the RTC of Makati, Branch 204.
The Manila RTC (Branch 24, Judge Antonio M. Eugenio, Jr.) denied the separate motions for intervention in a Joint Order dated August 8, 2007, citing Section 35 of the Rule of Procedure in Cases of Civil Forfeiture (A.M. No. 05‑11‑04‑SC), which prescribes a post‑forfeiture verified petition remedy for persons not impleaded or who did not intervene. The respondents’ motion for reconsideration was denied by the Manila RTC in an Order dated January 10, 2008. Respondents elevated the matter to the Court of Appeals by petition for certiorari.
In a Decision dated May 21, 2009, the Court of Appeals (CA) (Garandang, J., with Punzalan‑Castillo and Rosario, JJ., concurring) granted the petition and held that the Manila RTC gravely abused its discretion in denying respondents’ motions to intervene, finding that respondents had demonstrated assignee rights in the insolvency case and that Section 35 did not prohibit intervention prior to an order of forfeiture. The CA denied reconsideration in a Resolution dated May 17, 2010. The Republic filed a petition for review on certiorari to the Supreme Court under Rule 45.
While the Rule 45 petition was pending before the Court, the Manila RTC rendered final Decisions in the underlying forfeiture cases—Decision dated September 23, 2010 (Civil Case No...(Subscriber-Only)
Issues:
- Is the petition for review on certiorari moot and academic in light of the RTC’s subsequent forfeiture decisions?
- Did the Manila RTC commit grave abuse of discretion in denying respondents’ Motions for Leave to Intervene and Admit Attached Answer‑in‑Intervention in the civ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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