G.R. No. 77663 - Presidential Commission on Good Government vs. Pena

After the 1986 EDSA revolution, President Corazon C. Aquino issued Executive Order No. 1 (February 28, 1986), creating the Presidential Commission on Good Government (PCGG) tasked to recover ill-gotten wealth accumulated by former President Ferdinand Marcos, his family, relatives, associates, nominees, etc.
PCGG was vested with broad powers including:

The 1987 Constitution (Article XVIII, Sec. 26) and Executive Order No. 14 (May 7, 1986) confirmed PCGG’s authority and placed cases involving ill-gotten wealth under exclusive and original jurisdiction of the Sandiganbayan, subject only to certiorari review by the Supreme Court.

The Controversy over American Inter-Fashion Corporation and De Soleil Apparel Manufacturing Corporation

Two export garment firms, American Inter-Fashion Corporation and De Soleil Apparel Manufacturing Corporation, were allegedly organized under joint venture agreements with 67% stock held by Filipino "Local Investors" (represented by Renato Z. Francisco and Atty. Gregorio R. Castillo) and 33% by Hongkong investors (respondents Yeung Chun Kam and Yeung Chun Ho).
PCGG issued a freeze order on these firms’ assets on March 25, 1986, and appointed Ms. Noemi L. Saludo as Officer-in-Charge (OIC) with full management authority.
Subsequent authorizations of signatories for bank transactions were changed by the PCGG OIC in a February 3, 1987 memorandum, revoking prior authorizations to Yim Kam Shing (representing respondents) on grounds of immigration status issues, and designating new co-signatories.
Respondents Yeung Chun Kam, Yeung Chun Ho, and Archie Chan, through Yim Kam Shing, filed a damages action with an application for preliminary injunction before the Regional Trial Court (RTC) at Pasig Branch 152, challenging the revocation and seeking to enjoin the bank and PCGG from enforcing the memorandum.

RTC judge granted ex parte a temporary restraining order (TRO) on February 16, 1987, restraining the Commission and bank from acting on the memorandum and releasing funds without Yim Kam Shing’s signature.
PCGG moved to dismiss for lack of jurisdiction and argued that even assuming jurisdiction, respondents as minority shareholders were not entitled to such injunction.
RTC judge denied the motion and granted a preliminary injunction on March 5, 1987.
PCGG filed this special civil action for certiorari, prohibition, and mandamus, questioning RTC’s jurisdiction and seeking to set aside the TRO and injunction orders and to prohibit further proceedings.

On March 24, 1987, the Supreme Court issued a TRO against the RTC proceedings subject to conditions limiting PCGG’s withdrawals to necessary expenses and salary payments.

The PCGG has exclusive administrative jurisdiction over sequestration cases involving ill-gotten wealth under Executive Orders and the Constitution.
All civil or criminal cases related to ill-gotten wealth are exclusively lodged with the Sandiganbayan.
PCGG members are immune from suit for acts done in official discharge of their duties under Executive Order No. 1.
The Court addresses issues of police power, due process, administrative jurisdiction, and the need to prevent fragmentation of jurisdiction and multiplicity of suits.
The petition involves complex issues of ownership, control, and alleged ill-gotten wealth vis-à-vis claims of minority shareholders and other parties.

Whether the Regional Trial Court has jurisdiction over the PCGG and the properties sequestered and managed by the PCGG in the exercise of its powers under Executive Orders Nos. 1, 2, and 14, as amended.

Whether regional trial courts can restrain, set aside, or interfere with the orders and actions of the PCGG regarding ill-gotten wealth and properties placed in custodia legis.

The scope and exclusivity of jurisdiction of the PCGG and the Sandiganbayan over cases involving recovery of ill-gotten wealth seized from the Marcos regime.

The extent of immunity from suit enjoyed by the PCGG and its members under the Executive Orders.

The appropriateness of invoking judicial remedies like injunction and damages suits against the PCGG in the performance of its functions.