Case Summary (G.R. No. 138894)
Background and Executive Order
On February 28, 1986, Executive Order No. 1 was issued by former President Corazon C. Aquino to create the PCGG. This body was tasked with recovering assets acquired by Ferdinand E. Marcos and affiliated parties through illegal means. The PCGG was granted extensive powers, including the authority to takeover business entities tied to Marcos and his associates.
Filing of Complaint and Docket Fees
On April 17, 1998, the petitioners filed a complaint in the Sandiganbayan, seeking a declaration of ownership of shares from Eastern Telecommunications Philippines, Inc. (ETPI) that had previously been agreed upon in a compromise settlement between former Ambassador Roberto S. Benedicto and the Republic of the Philippines. The petitioners only paid a diminutive filing fee of ₱4,850 but were later challenged by the Sandiganbayan regarding the insufficiency of this amount as outlined in the Revised Rules of Court.
Jurisdiction and Filing Fees Dispute
After the pre-trial on October 9, 1998, the Sandiganbayan placed proceedings in abeyance due to the petitioners’ alleged failure to pay the correct filing fees, which would amount to approximately ₱1,326,955 based on the nature of their claim regarding ownership of the shares. The Sandiganbayan issued an order on October 14, 1998, requiring the petitioners to justify the complaint's continuation in light of the outstanding fees.
Petitioners' Response and Legal Arguments
In their response, the petitioners contended that the imposition of the fee structure under current rule amendments would trespass on their substantive rights as guaranteed under earlier Presidential Decree No. 1606. They argued that specific sections of Republic Act (R.A.) Nos. 7975 and 8249 did not expressly revoke previous legislation granting them privilege against filing fees.
Sandiganbayan's Resolution
On February 15, 1999, the Sandiganbayan dismissed the petitioners’ case from its call docket for lack of jurisdiction due to the failure to meet the prescribed filing fee guidelines. The petitioners subsequently sought reconsideration of this dismissal, but their motion was denied on May 24, 1999.
Supreme Court Review and Decision
The Supreme Court ultimately upheld the Sandiganbayan's dismissal, referencing previous cases, including the 2000 Yuchengco v. Republic of the Philippines decision. The Court reiterated that payment of the appropriate docket fees is necessary for jurisdiction and that the changes in the law regarding filing fees in civil cases had altered the context significantly, as the Sandiganbayan's expansion to include civil jurisprudence indicated an implied amendment of prior rulings.
Rationale on Filing Fees and Prescription
The Court outlines that for a trial court to gain jurisdiction, both the filing of a complaint and the
...continue readingCase Syllabus (G.R. No. 138894)
Introduction
- The case involves a petition for review on certiorari filed under Rule 45 of the 1997 Rules of Civil Procedure.
- The petitioners, the heirs of the late President Ferdinand E. Marcos, challenge the resolution of the Sandiganbayan dated February 15, 1999, which dismissed their complaint for lack of jurisdiction due to nonpayment of the correct docket fees.
Background of the Case
- On February 28, 1986, Executive Order No. 1 was issued by former President Corazon C. Aquino, establishing the Presidential Commission on Good Government (PCGG).
- The PCGG's mandate included the recovery of ill-gotten wealth associated with former President Ferdinand E. Marcos, his family, and associates.
- The PCGG was empowered to sequester business enterprises owned or controlled by those parties.
Relevant Legal Actions
- Various civil actions were initiated by the PCGG against individuals believed to hold property acquired through corrupt means, including former Ambassador Roberto S. Benedicto.
- A compromise agreement was reached on November 3, 1990, between Benedicto and the Republic of the Philippines, wherein Benedicto surrendered 51% of his equity in Eastern Telecommunications Philippines, Inc. (ETPI) to the PCGG.
Petitioners' Complaint
- On April 17, 1998, the petitioners filed a complaint against the PCGG, asserting ownership of shares ceded by Benedicto.
- The petitioners sought a declaration of ownership, an accounting of shares, and damages, paying an initial fil