Case Summary (G.R. No. 83831)

Case Overview

• Date of Decision: January 9, 1992
• Consolidated Cases: G.R. No. 83831, G.R. No. 85594, G.R. No. 85597, G.R. No. 85621
• Key Parties:
  • Petitioner: Victor Africa and others
  • Respondents: Presidential Commission on Good Government (PCGG) and its nominees

Jurisdiction and Consolidation of Cases

• Legal Principle: The Supreme Court consolidated four cases involving issues related to the sequestration of Eastern Telecommunications Philippines, Inc. (ETPI) by the PCGG.
• Context: The consolidation was based on a resolution from November 22, 1988, due to the relatedness of the cases arising from the sequestration and subsequent civil actions.

• The PCGG sequestered ETPI on March 14, 1986. • Civil Case No. 0009 was filed on July 22, 1987, by the PCGG for reconveyance and restitution of alleged ill-gotten shares.

Employment and Ouster Claims

• Case G.R. No. 83831: Victor Africa petitioned for an injunction against the PCGG and its appointees, claiming wrongful ousting from several corporate roles.
• Legal Grounds: Africa claimed that the reasons for his ousting were arbitrary and discriminatory, threatening his livelihood and family welfare.

• A temporary restraining order was sought to maintain his positions until legal determinations were made. • Claims of harassment and asset dissipation were raised against the PCGG-sponsored board.

Injunction and Damages Actions

• Cases G.R. Nos. 85594, 85597, and 85621: Other stockholders challenged the appointment of Eduardo M. Villanueva and others as directors of ETPI, alleging lack of due process.
• Legal Arguments: The petitioners argued that their removals were unlawful and sought injunctions to prevent the PCGG from interfering in ETPI's management.

• The PCGG's nominees filed motions to dismiss citing lack of jurisdiction and that plaintiffs were not real parties in interest. • The Sandiganbayan's jurisdiction to hear these cases was contested.

Court Rulings on Jurisdiction

• Supreme Court's Position: The Sandiganbayan has exclusive and original jurisdiction over cases involving ill-gotten wealth and related incidents.
• Key Precedents: The court cited previous rulings affirming the Sandiganbayan's jurisdiction over cases filed by the PCGG under Executive Order No. 14.

• The principle of state immunity from suit does not extend to injunction actions seeking to protect proprietary rights. • Complaints for injunction do not convert into claims against the state, thus maintaining jurisdiction.

Procedural Developments

• Subpoenas Issued: The Sandiganbayan ordered the PCGG to produce corporate records, which the PCGG contested.
• Court Rulings: The Supreme Court upheld the Sandiganbayan's authority to issue subpoenas for corporate records in the context of the ongoing cases.

• The PCGG's argument about res judicata was rejected as previous cases did not resolve the merits of the claims regarding the il...continue reading

Case Syllabus (G.R. No. 83831)

Case Overview

• The cases originate from the sequestration of Eastern Telecommunications Philippines, Inc. (ETPI) by the Presidential Commission on Good Government (PCGG) on March 14, 1986.
• The PCGG filed an action for reconveyance, reversion, accounting, restitution of alleged ill-gotten ETPI shares, and damages on July 22, 1987, docketed as Civil Case No. 0009 in the Sandiganbayan.
• The cases involve issues surrounding the legitimacy of actions taken by the PCGG and its nominees regarding the management and control of ETPI.

Consolidation of Cases

• The Supreme Court consolidated the four cases due to their interconnectedness concerning the sequestration of ETPI.
• The cases include:
  • G.R. No. 83831: Victor Africa vs. PCGG and its nominees.
  • G.R. No. 85594: PCGG and its nominees vs. the Sandiganbayan.
  • G.R. No. 85597: PCGG vs. Sandiganbayan.
  • G.R. No. 85621: Eduardo M. Villanueva vs. Sandiganbayan and PCGG.

Background of the Sequestration

• ETPI was partially sequestered, with 40% of shares released in May 1986 while 60% remained under sequestration.
• A stockholders meeting on January 29, 1988, led to the election of new board members, including PCGG nominees, triggering disputes over management control.

G.R. No. 83831: Victor Africa's Petition

• Victor Africa filed a petition for injunction on June 30, 1988, to prevent his ousting from multip...continue reading