Facts:

The case involves multiple petitions consolidated under G.R. Nos. 184622, 184712-14, 186066, and 186590, concerning an intra-corporate dispute among the Philippine Overseas Telecommunications Corporation (POTC), Philippine Communications Satellite Corporation (PHILCOMSAT), and Philcomsat Holdings Corporation (PHC). The petitioners include POTC and PHILCOMSAT, represented by various individuals, while the respondents include Victor Africa, Erlinda I. Bildner, Sylvia K. Ilusorio, Honorio Poblador III, and others. The events leading to the case began with the ownership of 5,400 shares of POTC stock, which became a point of contention among several families, including the Ilusorio, Nieto, Poblador, Africa, Benedicto, Ponce Enrile, and Elizalde families.

The shares were allegedly taken from Atty. Potenciano Ilusorio during the Marcos regime through intimidation and were later placed under the names of corporations associated with the Marcos family. Following the EDSA People Pow...

Facts:

Corporate Background

1. POTC, PHILCOMSAT, and PHC: Philippine Overseas Telecommunications Corporation (POTC) and Philippine Communications Satellite Corporation (PHILCOMSAT) are domestic corporations involved in telecommunications. Philcomsat Holdings Corporation (PHC), formerly Liberty Mines, Inc., is a holding company. POTC controls 100% of PHILCOMSAT, which in turn holds 81% of PHC.

2. Ownership Structure: POTC was owned by seven families, including the Ilusorio, Africa, Poblador, Benedicto, Ponce Enrile, Nieto, and Elizalde families. Atty. Potenciano Ilusorio, patriarch of the Ilusorio Family, claimed ownership of 5,400 POTC shares, which he alleged were taken by the Marcoses through threats and intimidation.

Sequestration by PCGG

3. PCGG Intervention: After the 1986 EDSA Revolution, the Presidential Commission on Good Government (PCGG) was created to recover ill-gotten wealth. Jose Y. Campos, a Marcos crony, surrendered assets, including shares in POTC held by Independent Realty Corporation (IRC) and Mid-Pasig Land Development (Mid-Pasig), to the PCGG.

4. Compromise Agreement: In 1996, a compromise agreement was reached between the Republic (through PCGG) and Atty. Ilusorio. The Republic acknowledged Ilusorio’s ownership of 673 POTC shares, while Ilusorio recognized the Republic’s ownership of 4,727 shares. The Sandiganbayan approved the agreement in 1998.

Intra-Corporate Disputes

5. Control Battles: The compromise agreement shifted control of POTC, PHILCOMSAT, and PHC. The Ilusorio Family, allied with the Africa, Poblador, Benedicto, and Ponce Enrile Families, gained majority control, while the PCGG’s control was reduced.

6. Litigation: Multiple legal battles ensued over control of the corporations, including disputes over board elections, withdrawals of corporate funds, and injunctions. The cases involved the Locsin Group (representing POTC, PHILCOMSAT, and PHC) and the Ilusorio Group.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Jurisdiction: Intra-corporate disputes, even involving sequestered corporations, are within the jurisdiction of the RTC under the Interim Rules of Procedure for Intra-Corporate Controversies. The Sandiganbayan’s jurisdiction is limited to cases involving the recovery of ill-gotten wealth.
2. Injunctive Relief: A party seeking injunctive relief must show a clear and unmistakable right to be protected. The Bildner Group met this requirement, as their election to the PHC Board was valid and enforceable.
3. Forum Shopping: Forum shopping occurs when a party files multiple cases involving the same issues to obtain a favorable judgment. Here, the cases involved distinct issues and parties, so forum shopping was not present.
4. Contempt of Court: Contempt powers are drastic and should be used sparingly. The Locsin Group’s actions, while contentious, did not rise to the level of clear and willful disobedience of court orders.
5. Factual Findings: The Supreme Court is not a trier of facts and will not reexamine evidence already reviewed by the lower courts. The factual findings of the CA and RTC are binding and conclusive.

Disposition

The Supreme Court:

• Denied the petitions in G.R. No. 184622, G.R. No. 184712-14, and G.R. No. 186066.
• Affirmed the Sandiganbayan’s resolution and the CA’s consolidated decision.
• Granted the petition in G.R. No. 186590, annulling the CA’s decision and reinstating the RTC’s writ of injunction.
• Directed the Locsin/Nieto-PCGG Group to account for and return funds to the corporations.