G.R. No. 215527-28 - Presidential Commission on Good Government vs. Cojuangco Jr.

Petitioners include the Presidential Commission on Good Government (PCGG) and several individual nominees (Julieta C. Bertuben, Ide C. Tillah, Emmanuel E. Cruz, Sergio Osmeña III, Tirso Antiporda Jr., Victor S. Ziga, Luis M. Mirasol, Jr., Jose Y. Feria).
Respondents include Eduardo M. Cojuangco Jr., Enriquez M. Cojuangco, Manuel M. Cojuangco, Estelito P. Mendoza, and Gabriel L. Villareal.

In 1995, at the annual stockholders' meeting of San Miguel Corporation (SMC), petitioners and respondents vied for seats in the SMC Board of Directors.
PCGG registered shares of stock (hereinafter Corporate Shares) belonging to 43 corporate stockholders in the names of their nominees (individual petitioners) to qualify for Board seats. PCGG voted these Corporate Shares in favor of their nominees.
Mendoza, acting as proxy for the corporate shareholders, voted the Corporate Shares in favor of the respondents.
Despite Mendoza's votes, the individual petitioners were declared elected; respondents were not.
Mendoza protested, challenging PCGG's authority to vote the Corporate Shares and the improper registration of said shares under the individual petitioners' names (who allegedly did not own the minimum required 5,000 shares by SMC By-laws). The SMC corporate secretary, Jose Feria, overruled the protest.
This instigated the filing of quo warranto petition Civil Case SB No. 0166 by respondents.

In 1996, a similar election occurred where PCGG nominees were again declared elected over the respondents.
Respondents filed another quo warranto petition, Civil Case SB No. 0169.

The Sandiganbayan initially dismissed both quo warranto petitions for lack of jurisdiction in May 1995 and 1996.
Respondents elevated the issue to the Supreme Court in *Cojuangco, Jr. v. Sandiganbayan*, which held that Sandiganbayan has jurisdiction over quo warranto petitions related to PCGG cases on alleged ill-gotten wealth as per Executive Order No. 14.
The Court remanded the case for further proceedings.

Petitioners filed a Motion to Dismiss in SB No. 0166 citing mootness due to expiry of office terms, and a Motion to Hold in Abeyance in SB No. 0169 citing a pending similar issue in G.R. No. 115352.
Respondents opposed, arguing the issues were still relevant and that G.R. No. 115352 involved a different election year.
Feria initially sought suspension to file pleadings but later filed an Answer.
The Sandiganbayan treated motions by petitioners as substantial compliance with orders despite lack of proper responsive pleadings.

On July 15, 2014, the Sandiganbayan partially granted respondents’ quo warranto petitions, declaring the 1995 and 1996 election of PCGG nominees to the SMC Board null and void.
It ruled that PCGG had no authority to vote the Corporate Shares, which authority belongs to the registered owners or their proxies, citing the Court’s rulings in *BASECO* and *Republic v. Sandiganbayan*.
The Sandiganbayan refused to declare respondents as duly elected members due to lack of proof that Mendoza voted on their behalf via proxy.
Petitioners’ motion for reconsideration based on mootness and *Republic* was denied in a November 25, 2014 resolution.

Petitioners assail the Sandiganbayan’s decision and resolution, invoking mootness and denial of due process arguments.
Respondents counter that the exceptions to mootness apply and due process was afforded.

Whether the quo warranto petitions are moot and academic due to the expiration of the PCGG nominees' term and subsequent related Supreme Court rulings.
Whether the PCGG has the authority to vote the sequestered Corporate Shares of SMC during the elections in question.
Whether the Sandiganbayan committed grave abuse of discretion by resolving the case on the merits without allowing petitioners opportunity for due process regarding their failure to file responsive pleadings.
Whether exceptions to the mootness doctrine apply to maintain justiciability.