Case Digest (G.R. No. 106413)
Facts:
Republic of the Philippines, G.R. No. 106413, July 05, 1996, Supreme Court Second Division, Mendoza, J., writing for the Court. The petition challenges two resolutions of the Second Division of the Sandiganbayan (October 1, 1991 and July 23, 1992) and alternatively seeks writ of mandamus compelling the Sandiganbayan to hear whether the Price Mansion in Tacloban City is ill-gotten property.On March 18, 1986 the Presidential Commission on Good Government (PCGG) sequestered two lots and a building collectively known as the Price Mansion, believing them to be assets of Benjamin “Kokoy” Romualdez. Tacloban City Ice Plant, Inc. (TCIP) asserted ownership, claiming acquisition by a Deed of Extrajudicial Partition and Sale in March 1978. After hearings, the PCGG concluded TCIP had “sufficiently substantiated its claim to bonafide ownership” and issued an order dated February 1987 lifting the sequestration of the Price Mansion. Despite that order, the PCGG listed the property among assets in Civil Case No. 0035 filed in the Sandiganbayan on August 13, 1987, and kept physical possession.
TCIP pressed for deletion of the property from the complaint annex and for turnover. On June 28, 1989 the Sandiganbayan granted TCIP’s Motion to Exclude Sequestered Property, ordered deletion of the Price Mansion from Romualdez’s asset list, and directed the PCGG and the Office of the Solicitor General to effect turnover to TCIP. The PCGG, however, did not make full turnover; part of the premises was occupied by an antenna of PRTV-12.
In February 1990 TCIP sold the Price Mansion to Allied Banking Corporation as trustee for College Assurance Plan Philippines, Inc. (CAPP), with a contractual obligation to remove the antenna and deliver possession. When turnover was not completed, TCIP filed a Motion for Compliance on March 22, 1991. On October 1, 1991 the Sandiganbayan granted the motion for compliance and declared its June 28, 1989 resolution final and executory, ordering complete turnover within thirty days.
The Republic (through PCGG/Solicitor General) filed a motion for reconsideration, alleging new evidence that TCIP had earlier sold the Price Mansion to Universal Broadcasting Corporation (UBC) (a sequestered entity with ties to Romualdez and Zenaida Ocampo), and arguing that the property “may be ill-gotten” after all. UBC filed a Complaint in Intervention claiming ownership and asserting a 15 December 1981 Deed of Absolute Sale; it also alleged it had possession and had erected the antenna. On June 16, 1992 the Sandiganbayan denied UBC’s motion to intervene, saying the dispute should be decided in a separate action. On July 23, 1992 the Sandiganbayan denied the Republic’s motion for reconsideration as moot and academic, reasoning that the June 28, 1989 resolution was final and that, once deleted from the sequestered assets, the pr...(Pro-only)
Issues:
- Did the Sandiganbayan commit grave abuse of discretion in declaring the Republic's motion for reconsideration moot and academic?
- Was the Sandiganbayan’s June 28, 1989 resolution deleting the Price Mansion from Romualdez’s assets a final and executory determination as to ownership vis‑à‑vis Benjamin Romualdez?
- Should the Sandiganbayan have conducted a hearing to determine UBC’s asserted ownership and the PCGG’s right to retai...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)