Case Digest (G.R. No. 88537)
Facts:
The Republic of the Philippines, through the Presidential Commission on Good Government (PCGG), filed with the Sandiganbayan a complaint for reconveyance, reversion, accounting, restitution and damages (Civil Case No. 0024) against Ferdinand E. Marcos, Imelda R. Marcos, and several others, docketed on July 29, 1987 and amended/expanded on January 25, 1988, involving, among others, the shares of stock in Lianga Bay Logging Corporation and two parcels of land in Palawan known as the Yulo King Ranch.
Workers of Lianga Bay Logging Corporation and Philippine Agri-Business Corporation moved to intervene with their respective complaints-in-intervention, which the Sandiganbayan admitted in resolutions dated November 9, 1988 and November 11, 1988. The Republic sought certiorari, prohibition, and in the alternative mandamus to nullify and dismiss the intervention complaints, arguing lack of jurisdiction, absence of legal interest, and State immunity from suit; the petition was resolved against it.
Issues:
- Whether the Sandiganbayan committed reversible error in admitting the complaints-in-intervention under Rule 12, Section 2 of the Rules of Court.
- Whether the intervention complaints improperly overcame State immunity from suit.
- Whether claims asserted by the intervenors were cognizable by the Sandiganbayan or properly belonged in the regular courts.
Ruling:
The Court dismissed the petition for lack of merit and upheld the Sandiganbayan’s resolutions admitting the intervention complaints.
It held that the Sandiganbayan acted within its discretion in allowing intervention upon a finding of direct, actual, and material legal interests, and that the intervention complaints did not constitute an impermissible suit against the State. It further ruled that jurisdiction over incidents related to PCGG cases for recovery of ill-gotten wealth lies exclusively with the Sandiganbayan, subject to review by the Supreme Court on certiorari.
Ratio:
The Court found support for the Sandiganbayan’s conclusion that the proposed intervenors had the requisite legal interest: as to Workers, the allegations tied their ownership of shares and alleged depredations to facts admitted by the pleadings, and as to Philippine Agri-Business, the land subject of the action was claimed by it as the rightful owner and was disputed among competing claimants in the same proceeding to avoid multiplicity of suits. The Court emphasized that once the trial court’s discretion to allow intervention is exercised, certiorari and mandamus will not lie absent a showing that the discretion was exercised arbitrarily or capriciously.
On immunity, the Court ruled that the intervention complaints were filed by the intervenors as plaintiffs by using the procedural mechanism for intervention and did not seek money judgment or affirmative performance from the State in its political capacity; they merely sought resolution of ownership disputes over sequestered properties that were incidents of the main Sandiganbayan case. It also rejected the argument that the intervenors’ claims belonged elsewhere, citing Presidential Commission on Good Government v. Hon. Pena (G.R. No. 77663, April 12, 1988) and related cases, which held that under Presidential Decree No. 1606 and Executive Order No. 14, the Sandiganbayan has exclusive and original jurisdiction over PCGG cases for ill-gotten wealth and all incidents arising from, incidental to, or related to such cases.
Doctrine:
- Under Rule 12, Section 2 of the Rules of Court, a court may allow intervention when the intervenor has a direct, actual, and material legal interest in the matter in litigation or in the success of the parties.
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