Case Digest (G.R. No. 147062-64) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the aftermath of the 1986 EDSA Revolution, President Aquino issued Executive Orders 1, 2, and 14 creating the Presidential Commission on Good Government (PCGG) to recover alleged ill-gotten wealth of the Marcos regime. Pursuant thereto, the PCGG sequestered shares of stock in the United Coconut Planters Bank (UCPB) registered in the names of over one million coconut farmers, Coconut Industry Investment Fund companies (CIIF), and private respondent Eduardo M. Cojuangco, Jr. On July 31, 1987, the PCGG filed Case No. 0033 before the Sandiganbayan for reconveyance, reversion, accounting, restitution, and damages relating to these shares. On November 15, 1990, the Sandiganbayan lifted the sequestration of the farmers’ and CIIF shares for failure to implead them within six months as required by the 1987 Constitution. The PCGG challenged that Resolution in G.R. No. 96073 before the Supreme Court. Meanwhile, the Sandiganbayan ordered UCPB to hold a stockholders’ meeting to elect a bo Case Digest (G.R. No. 147062-64) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Creation of PCGG and Sequestration
- After the 1986 EDSA Revolution, President Aquino issued EO Nos. 1, 2, and 14 creating the Presidential Commission on Good Government (PCGG) to recover ill-gotten wealth.
- PCGG sequestered various assets, including United Coconut Planters Bank (UCPB) shares registered in the names of “one million coconut farmers,” Coconut Industry Investment Fund (CIIF) companies, and Eduardo M. Cojuangco, Jr.
- Sandiganbayan Proceedings on UCPB Shares
- July 31, 1987: PCGG filed Civil Case No. 0033 in Sandiganbayan for reconveyance, reversion, accounting, restitution, and damages concerning UCPB shares.
- November 15, 1990: Sandiganbayan lifted sequestration of UCPB shares registered to private respondents for PCGG’s failure to implead them within the six-month constitutional period.
- Supreme Court Interventions
- G.R. No. 96073: PCGG petitioned to annul Sandiganbayan’s lifting of sequestration; SC issued a temporary restraining order (TRO) enjoining UCPB elections.
- March 3, 1992: SC lifted its TRO, allowed UCPB stockholders’ meeting, and permitted registered owners to vote sequestered shares.
- February 16, 1993: SC recalled March 3 order, reinstating PCGG voting rights pending final determination, citing the “public character” of coconut levy funds.
- January 23, 1995: SC decision in G.R. No. 96073 nullified Sandiganbayan’s lifting of sequestration and confirmed PCGG’s TROs; maintained PCGG’s right to vote pending final resolution.
- Events Leading to the Assailed Order
- February 13, 2001: COCOFED et al. and Ballares et al. demanded a UCPB stockholders’ meeting on March 6, 2001 to elect directors.
- February 23, 2001: They filed a “Class Action Omnibus Motion” seeking to enjoin PCGG from voting UCPB and certain San Miguel Corporation shares.
- February 28, 2001: Sandiganbayan (First Division) issued an order allowing registered stockholders (COCOFED, Ballares, Cojuangco) to vote sequestered UCPB shares and setting a bond requirement.
Issues:
- Substantive Issue
- Who may exercise the right to vote sequestered UCPB shares pending final adjudication of their ownership?
- Procedural Issue
- Did the Sandiganbayan commit grave abuse of discretion and violate due process by issuing its February 28, 2001 order enjoining PCGG from voting the sequestered shares?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)