Case Digest (G.R. No. 136506)
Facts:
The petition stems from Civil Case No. 0008 before the Sandiganbayan, filed on July 21, 1987 by the Presidential Commission on Good Government (PCGG) on behalf of the Republic of the Philippines to recover alleged ill-gotten wealth of Ferdinand and Imelda Marcos and their associates. Private respondents Bienvenido R. Tantoco, Jr. and Dominador R. Santiago were impleaded alongside other Marcos-related parties. After summons, respondents filed on November 3, 1987 a “Motion to Strike Out Some Portions of the Complaint and for Bill of Particulars,” which the PCGG opposed. On January 29, 1988 the Sandiganbayan ordered the PCGG to submit a more specific complaint, and respondents sought leave to serve interrogatories under Rule 25. The PCGG moved to strike those interrogatories. On March 18, 1988, the PCGG filed its Expanded Complaint; respondents renewed their bill of particulars motion on April 11, 1988. By Resolution of July 4, 1988, the Sandiganbayan denied motions to strike, forCase 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)