Case Digest (G.R. No. 89425)
Facts:
Republic of the Philippines (represented by the Presidential Commission on Good Government) v. Sandiganbayan, Second Division, and Rebecco Panlilio, G.R. No. 89425, February 25, 1992, the Supreme Court En Banc, Narvasa, C.J., writing for the Court.The PCGG, acting under executive sequestration powers, issued a writ on May 31, 1986 placing several firms (including Silahis International Hotel, Hotel Properties, Inc., and Philroad Construction Corporation) under sequestration and later filed a civil complaint in the Sandiganbayan for reversion, reconveyance, restitution, accounting and damages against twelve named defendants including Rebecco Panlilio and members of the Marcos circle. More than a year after the writ, on July 28, 1989, the PCGG issued Mission Order No. AD-89-51 creating a Management Committee to take over management and operations of Silahis Hotel, citing labor unrest and the need to protect government interests.
On August 3, 1989 Panlilio filed with the Sandiganbayan a Motion for Injunction with Application for Restraining Order alleging the PCGG’s takeover exceeded sequestration powers, that the Hotel was profitable and that the seizure was abusive and unnecessary. The Sandiganbayan (Second Division) heard the motion and on August 14, 1989 issued a Resolution enjoining the PCGG and its Management Committee from implementing Mission Order No. AD-89-51, concluding that Panlilio had presented evidence showing no dissipation of assets and finding that the PCGG had not presented countervailing evidence at that time.
PCGG sought relief from this Court by filing, August 16, 1989, a petition for certiorari and prohibition with urgent prayer for preliminary injunction/TRO. On September 5, 1989 the Supreme Court did not restrain the Sandiganbayan; rather it referred PCGG’s urgent motion to the Sandiganbayan to be treated as a motion for reconsideration of its August 14 order and directed the Sandiganbayan to schedule hearings to receive the PCGG’s evidence and then decide whether to maintain, lift or modify its order.
Conforming to the Supreme Court’s directions, the Sandiganbayan scheduled hearings and received evidence on September 15, 18 and 20, 1989. After reviewing the additional submissions, the Sandiganbayan on October 27, 1989 issued a Resolution reaffirming its August 14 disposition, expressly finding that Mission Order No. AD-89-51 had no factual or legal basis, declaring the mission order null and void ab initio, and ordering the PCGG to divest itself of participation in the hotel’s management except as permitted by guidelines previously enunciated in earlier sequestration cases.
The PCGG filed an Urgent Supplemental Petition with this Court (filed November 23, 1989) contending that the Sandiganbayan exceeded the limited t...(Pro-only)
Issues:
- Did the Sandiganbayan exceed its jurisdiction or otherwise act with grave abuse of discretion in reviewing and enjoining the PCGG’s Mission Order No. AD-89-51 and takeover of Silahis Hotel?
- Whether Mission Order No. AD-89-51 and the PCGG's Management Committee takeover were valid or void ab initio under the evidence and applicable law?
- What is the proper scope of judicial review by the Supreme Court of Sandiganbayan factual findings in cas...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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