Title
Republic vs. Sandiganbayan
Case
G.R. No. 90478
Decision Date
Nov 21, 1991
PCGG challenged Sandiganbayan's allowance of interrogatories and document production in a case involving reconveyance and damages, claiming privilege and abuse of discretion. Supreme Court ruled PCGG, as plaintiff, waived immunity and must comply with discovery rules.
A

Case Digest (G.R. No. 136506)

Facts:

  • Parties and Case Background
    • On July 21, 1987 the Presidential Commission on Good Government (PCGG), in behalf of the Republic, filed Civil Case No. 0008 before the Sandiganbayan against Ferdinand E. Marcos, Imelda R. Marcos, Bienvenido R. Tantoco Jr., Dominador R. Santiago and others for reconveyance, reversion, accounting, restitution and damages under Executive Order No. 14.
    • Respondents Tantoco Jr. and Santiago were served with summons but did not answer; they filed motions to strike portions of the complaint and for a bill of particulars.
  • Procedural History
    • January 29, 1988 – Sandiganbayan ordered PCGG to expand its complaint; March 18, 1988 – PCGG filed an expanded complaint.
    • Respondents sought leave to serve interrogatories (Feb 1, 1988) and later served amended interrogatories and moved for production and inspection of documents (July–August 1989).
    • August 21 & 25, 1989 – Sandiganbayan admitted the interrogatories and granted document production; September 29, 1989 – Sandiganbayan denied PCGG’s motions for reconsideration.
    • October 1989 – PCGG petitioned the Supreme Court for certiorari and obtained a temporary restraining order. Solicitor General withdrew; case submitted for decision.

Issues:

  • Interrogatories to PCGG
    • Whether the Sandiganbayan erred in allowing respondents to serve interrogatories that did not name specific PCGG officers.
    • Whether the interrogatories impermissibly sought evidentiary details already denied by the bill of particulars.
  • Production and Inspection of Documents
    • Whether respondents showed good cause under Rule 27 to inspect and copy PCGG documents.
    • Whether the documents were privileged, confidential under Executive Order No. 1, non-existent, or already in evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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