G.R. No. 105938 - Regala vs. Sandiganbayan

Case Digest (G.R. No. 105938)
Expanded Legal Reasoning Model

Facts:

Parties and Background

Petitioners Teodoro R. Regala, Edgardo J. Angara, Avelino V. Cruz, Jose C. Concepcion, Rogelio A. Vinluan, Victor P. Lazatin, Eduardo U. Escueta, and Paraja G. Hayudini were partners in the ACCRA Law Firm.
Private respondent Raul S. Roco was also then a partner in the ACCRA Law Firm.
Respondent Presidential Commission on Good Government (PCGG) filed Civil Case No. 0033 before the Sandiganbayan against Eduardo M. Cojuangco Jr. and various defendants, including the petitioners, for recovery of alleged ill-gotten coconut levy funds and related corporate shares.

Organizational and Nominee Transactions

The ACCRA Law Firm performed legal services for clients, including incorporation and acquisition of corporations, and acted as incorporators or nominees-stockholders.
In course of services, ACCRA lawyers took delivery of unsigned stock certificates and blank deeds of assignment covering client shareholdings, and acquired confidential information on client assets and transactions.
Petitioners and Roco admit they acted as nominee-stockholders for clients in numerous coconut levy–funded corporations enumerated in the Complaint.

Third Amended Complaint and Exclusion of Roco

On August 20, 1991, PCGG filed a “Third Amended Complaint” excluding Roco as a defendant, allegedly on his undertaking to identify his principal(s).
Petitioners moved for identical exclusion but PCGG conditioned it on:

Disclosure of the identity of their client(s);
Submission of documents substantiating the lawyer-client relationship; and
Submission of deeds of assignment executed in favor of their client(s).

Proceedings Below

PCGG presented letters and an affidavit from Roco’s counsel, asserting Roco’s willingness to cooperate, though petitioners contend Roco did not in fact identify his client(s).
On March 18, 1992, the Sandiganbayan First Division denied petitioners’ counter-motion to exclude them, holding that until petitioners identify their clients the existence of privilege could not be debated.
The Sandiganbayan likewise denied petitioners’ motion for reconsideration on May 21 and September 3, 1992.

Recourse to the Supreme Court

Petitioners filed two certiorari petitions in the Supreme Court (G.R. Nos. 105938 and 108113), contending:

Sandiganbayan gravely abused its discretion in ignoring the attorney-client privilege;
Petitioners and Roco were similarly situated, yet Roco was given preferential treatment in violation of equal protection;
The conditions to drop petitioners as defendants were unreasonable and violated their constitutional rights.

Issues:

Discretion and Agency Law

Did the Sandiganbayan commit grave abuse of discretion by treating petitioners as defendants under strict agency law to force disclosure of client identity?

Equal Protection

Did Sandiganbayan and PCGG deny petitioners equal protection by excluding Roco but retaining petitioners without reasonable distinction?

Attorney-Client Privilege

Under Philippine law and given these facts, does the attorney-client privilege prohibit petitioners from disclosing the identity of their client(s) or related documents?

Conditions to Exclusion

Must PCGG’s dropping of defendants be based on reasonable and just grounds, respecting the petitioners’ rights to confidentiality and against self-incrimination?

Ruling:

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Ratio:

(Subscriber-Only)

Doctrine:

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Case Digest (G.R. No. 105938) Core Legal Reasoning Model Expanded

Facts:

Case Digest (G.R. No. 105938) Expanded Legal Reasoning Model

Facts:

Issues:

Ruling:

Ratio:

Doctrine:

Case Digest (G.R. No. 105938)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. 105938)
Expanded Legal Reasoning Model