Case Digest (G.R. No. 209447)
Facts:
Presidential Commission on Good Government (PCGG) v. Hon. Winlove M. Dumayas, Regional Trial Court, Branch 59, Makati City, and United Coconut Planters Bank (UCPB) / United Coconut Planters Life Assurance Corporation (COCOLIFE), G.R. Nos. 209447 and 210901, August 11, 2015, the Supreme Court En Banc, Villarama, Jr., J., writing for the Court.The factual backdrop is the long-running litigation over the coconut levy funds collected under various presidential decrees during the Marcos era and the assets acquired therewith (notably UCPB and a CIIF block of San Miguel Corporation shares). The Sandiganbayan rendered partial summary judgments in Civil Case Nos. 0033‑A (July 11, 2003) and 0033‑F (May 7, 2004), and this Court in COCOFED v. Republic (Jan. 24, 2012, with a Sept. 4, 2012 Resolution) affirmed that the coconut levy proceeds are public funds and adjudicated ownership of the CIIF companies and the CIIF block of SMC shares in favor of the Government for the benefit of coconut farmers.
On December 28, 2012, respondent UCPB filed a petition for declaratory relief in the RTC of Makati (Civil Case No. 12‑1251) claiming that not all capital used to establish the six CIIF oil‑mill companies and the 14 CIIF holding companies was sourced from coconut‑levy funds and asserting an 11.03% indirect ownership interest; COCOLIFE filed a similar petition (Civil Case No. 12‑1252) asserting an 11.01% interest. Both petitions sought declarations of rights based on corporate documents and stock certificates rather than directly attacking the Supreme Court decisions or seeking to lift sequestration.
PCGG moved to dismiss both petitions on multiple grounds: lack of subject‑matter jurisdiction (because such matters fall within the Sandiganbayan’s exclusive original jurisdiction over ill‑gotten wealth cases), the action being an impermissible collateral attack on final rulings in the Sandiganbayan and this Court, estoppel/laches due to prolonged inaction, and defective pleadings (including alleged improper verification and certification against forum shopping signed by only one PCGG commissioner and alleged failure to implead the Republic).
The RTC, Branch 59 (respondent judge), denied PCGG’s motions to dismiss (Order Apr. 29, 2013; Omnibus Order May 15, 2013) and denied motions for reconsideration (Order June 28, 2013; Order Dec. 4, 2013), directing PCGG to file answers. PCGG sought rel...(Pro-only)
Issues:
- Whether the verification and certification against forum shopping signed by only one PCGG Commissioner fatally defective the petitions.
- Whether the Regional Trial Court, Makati City (Branch 59) has subject‑matter jurisdiction over Civil Case Nos. 12‑1251 and 12‑1252.
- Whether the petitions for declaratory relief filed in the RTC complied with the requisites of a petition for declaratory relief.
- Whether res judicata (and/or laches) bars ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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