Case Digest (G.R. No. 113420)
Facts:
Republic of the Philippines, through the Presidential Commission on Good Government (PCGG), caused the issuance on March 19, 1986 of writs of sequestration against Provident International Resources Corporation and Philippine Casino Operators Corporation. The Republic filed Civil Case No. 0021 on July 29, 1987 against several individuals naming the respondent corporations among listed properties; the corporations filed a mandamus (Civil Case No. 0132) on September 11, 1991 to lift the sequestration for alleged noncompliance with Section 26, Article XVIII; the Sandiganbayan granted the corporations' motion on December 4, 1991 and denied reconsideration on October 27, 1993.
Issues:
- Whether the inclusion or listing of the sequestered corporations in Civil Case No. 0021 satisfied the constitutional requirement of filing the corresponding *judicial action or proceeding* within the period fixed in Section 26, Article XVIII of the Constitution?
- Whether the sequestration order dated March 19, 1986 was valid despite having been signed by only one PCGG Commissioner in view of the PCGG Rules and Regulations requiring authority of at least two commissioners?
Ruling:
The Court granted the petition, set aside the assailed Sandiganbayan Resolutions, and made the temporary restraining order permanent, directing the Sandiganbayan to proceed expeditiously to resolve the cases on the merits. The Court held that the filing of Civil Case No. 0021, which listed the corporations as repositories of alleged ill-gotten wealth and was later amended to implead them, complied with Section 26, Article XVIII, and that the March 19, 1986 sequestration was valid despite having been signed by one commissioner because the PCGG Rules and Regulations were promulgated thereafter.
Ratio:
Relying on the Court's prior exposition in Republic v. Lobregat, the Court reasoned that complaints which identify corporations as instruments, repositories or fruits of ill-gotten wealth constitute the corresponding judicial action or proceeding required by Section 26 and that impleading such corporations is often unnecessary or curable by amendment when warranted by the evidence. The Court further explained that the PCGG Rules and Regulations promulgated on April 11, 1986 could not be applied retroactively to invalidate a sequestration issued on March 19, 1986, and emphasized the overriding public policy to decide recovery-of-ill-gotten-wealth cases on their merits rather than on procedural technicalities.
Doctrine:
- Complaints that specifically identify or list corporations as repositories or instruments of alleged ill-gotten wealth satisfy the constitutional requirement of the corresponding *judicial action or proceeding* under Section 26, Article XVIII.
- (Get Pro to unlock 2 more doctrines)