Case Digest (G.R. No. 96073)
Republic of the Philippines v. Sandiganbayan (First Division), Maria Clara Lobregat, Bienvenido Marquez, Celestino Sabate, Jose R. Eleazar, Jr., Domingo Espina, Jose Gomez, Manuel Del Rosario, Jose Martinez, Jr., Jose Reynaldo Morente, Eladio Chatto, and Philippine Coconut Producers Federation, Inc., et al., G.R. Nos. 96073, 104065, 104167, 104168, 104679, 104850, 104883, 105170, 105205, 105206, 105711-12, 105808, 105809, 105850, 106176, 106765, 107233, 107908, 109314, 109592, EN BANC, January 23, 1995, Narvasa, C.J., writing for the Court.
Facts:
- The petitioning State actors — the Republic of the Philippines and the Presidential Commission on Good Government (PCGG) — sought judicial review of multiple resolutions of the Sandiganbayan that had set aside or declared lifted numerous orders of sequestration, freezing or provisional takeover issued by the PCGG in 1986–1988 under Executive Orders Nos. 1 and 2 and Proclamation No. 3. The sequestrations targeted a long list of persons and corporations allegedly holding or channeling the ill‑gotten wealth of the Marcos regime; the consolidated Supreme Court docket contains the many civil actions (e.g., Civil Case Nos. 0007, 0009, 0014, 0016, 0021, 0023, 0024, 0025, 0033, 0034, 0035) instituted by PCGG for reconveyance, accounting and restitution.
- The PCGG filed its Sandiganbayan complaints within the constitutionally prescribed periods but in many complaints it listed numerous corporations and corporate stockholders as instruments, repositories or fruits of alleged ill‑gotten wealth without formally impleading those corporations as defendants; instead PCGG described them in annexes (e.g., Annex A) and sought relief against the identified property and persons. Numerous sequestered corporations therefore moved in the Sandiganbayan to lift sequestration on the ground that no judicial action had been commenced against them individually within six months as required by Section 26, Article XVIII of the 1987 Constitution.
- The Sandiganbayan granted many of those motions and issued resolutions and injunctions declaring sequestrations automatically lifted or enjoining PCGG from exercising shareholder rights (decisions cited in the petitions). A parallel strand involved the INTERCO and PJI matters in which this Court had earlier sustained Sandiganbayan rulings limiting PCGG’s practice of relying on lists and non‑impleaded entities (see G.R. No. 92755 and G.R. No. 92376).
- The PCGG elevated those Sandiganbayan resolutions to the Supreme Court by special civil actions of certiorari (and related proceedings) challenging the lifting or modification of sequestrations; certain temporary restraining orders were entered by this Court in the course of litigation (e.g., TRO issued July 9, 1992 and related orders). The consolidated cases before the Court raise the legal qu...(Pro-only)
Issues:
- Does Section 26, Article XVIII of the 1987 Constitution require that corporations or business enterprises sequestered by the PCGG be formally and individually impleaded as defendants within the six‑month period to prevent automatic lifting of sequestration?
- If formal impleading were required, may the PCGG cure an omission to implead by amending its complaints after the constitutional six‑month period, and what is the effect on existing sequestrations?
- Were the challenged Sandiganbayan resolutions lifting sequestrations or directing delivery of property proper in light of the...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)