Title
Yuchengco vs. Sandiganbayan
Case
G.R. No. 149802
Decision Date
Jan 20, 2006
Republic failed to prove PTIC shares were ill-gotten; Sandiganbayan's dismissal upheld due to insufficient evidence and procedural compliance.

Case Digest (G.R. No. 207887)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The consolidated petitions involve several cases filed before the Supreme Court challenging certain interlocutory orders and the Partial Decision of the Sandiganbayan in Civil Case No. 0002.
    • The case centers on the recovery of allegedly “ill‐gotten wealth” purportedly amassed by former President Ferdinand E. Marcos and his close associates.
    • Among the disputed assets are shares of stock in the Philippine Telecommunications Investment Corporation (PTIC) that, in turn, is a major shareholder of Philippine Long Distance Telephone Company (PLDT).
    • The Republic, through the Presidential Commission on Good Government (PCGG), asserts that a grouping of shares held by Prime Holdings, Inc. (PHI) and shares held in the names of Ramon U. Cojuangco and Imelda Cojuangco actually belongs to the Marcoses.
  • Corporate Structure and Transactions
    • PHI was organized in 1977 by a group of incorporators and nominees—namely, Jose Yao Campos, Rolando C. Gapud, Renato E. Lirio, Gervasio Gaviola, and Ernesto S. Abalos—who, according to PCGG’s allegations, acted on behalf of President Marcos.
    • Standard operating procedures in dummy corporations for Marcos normally required:
      • The execution of Deeds of Trust or Deeds of Assignment in favor of an unnamed beneficiary or blank endorsement of stock certificates.
      • Delivery of such documents directly to the then-President to evidence his beneficial control.
    • In the PHI matter, however, evidence shows that:
      • Instead of recorded blank or unsigned assignments, PHI shares were assigned specifically to Ramon U. Cojuangco and later to members of the Cojuangco family.
      • Testimonies indicate that blank deeds or certificates were not delivered to Marcos but eventually ended up in the custody of Cojuangco, who later assumed control of PHI.
    • Additional transactions include:
      • The transfer on May 2, 1978, whereby Ramon U. Cojuangco and Luis T. Rivilla ceded a total of 111,415 PTIC shares to PHI.
      • Subsequent assignments in 1981 and 1983 wherein certain incorporators (or their nominees) transferred their PHI shareholdings to Ramon U. Cojuangco or his kin.
    • The Republic contends that these arrangements were designed to conceal the true beneficial ownership of PTIC (and indirectly of PLDT) by channeling the assets through a dummy corporation controlled by Marcos.
  • Procedural History and Presentation of Evidence
    • Multiple petitions were filed:
      • Petitions by the Republic (PCGG) challenged orders denying additional time to present evidence and motions to suspend trial pending discovery.
      • Petitions by intervening parties (Yuchengco and Y Realty) raised issues on their right to present evidence and questioned the reordering of the trial schedule.
    • During the separate trial on the PLDT share issue, the Sandiganbayan rendered a Partial Decision dismissing the complaint on the basis that the Republic failed to prove by preponderance of evidence that the disputed shares constituted ill‐gotten wealth.
    • The evidence presented largely comprised the depositions and sworn statements of key witnesses:
      • Jose Yao Campos testified that it was his practice to organize corporations on behalf of President Marcos and to execute standard deeds of trust/assignment.
      • Rolando Gapud, one of the incorporators, testified regarding the delivery and subsequent reassignment of PHI shares; however, his testimony indicated that his blank assignment documents were eventually replaced by assignments naming Cojuangco.
      • Atty. Francisco de Guzman, former corporate secretary, corroborated the organizational details of PHI, including the absence of properly issued stock certificates and the handling of documents according to a set “standard operating procedure.”
    • Discrepancies highlighted by the Republic include:
      • Inconsistencies in witness testimony regarding whether PHI’s deeds followed the usual “blank beneficiary” protocol.
      • Evidence that the assignments to Cojuangco did not conform to the pattern expected if PHI were truly a dummy vehicle for Marcos.
    • Procedurally, certain motions for reconsideration and requests for additional time were filed, yet issues of timeliness (under Rule 65) and due process arose, further complicating the remedial landscape.

Issues:

  • Evidentiary and Authenticity Concerns
    • Whether the Republic met its burden of proving by a preponderance of evidence that the PTIC and, by extension, the PLDT shares held by PHI are “ill‐gotten” wealth of the Marcoses.
    • Whether the documentary evidence—predominantly photocopies and affidavits—was sufficiently authenticated (in light of the Best Evidence and Hearsay Rules) to support the claim.
  • Corporate Ownership and Dummy Allegations
    • Whether PHI was organized and maintained as a dummy corporation for President Marcos, based on standard practices involving blank deeds or trust instruments, or whether the execution of assignments naming Ramon U. Cojuangco proves that the beneficial ownership lay with the Cojuangco family.
    • The implications of the absence of delivery of blank endorsements to President Marcos on the characterization of PHI’s shares.
  • Procedural Due Process and Trial Scheduling
    • Whether the orders of the Sandiganbayan—that denied motions for additional time to present evidence and declared certain parties as having waived their right to further evidence—violated the petitioners’ substantive due process rights.
    • Whether the trial court properly exercised its discretion in scheduling hearings in light of the right to a speedy trial versus the need for a full and fair opportunity to present evidence.
  • Timeliness of Appeals and Motions under Rule 65
    • Whether the petitions for certiorari (especially those filed by the Yuchengcos) were timely under Section 4 of Rule 65, considering the filing of motions for reconsideration and the subsequent receipt of orders.
    • Whether the interlocutory orders challenged had become final and therefore were non-appealable.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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