Title
Kant Kwong vs. Presidential Commission on Good Government
Case
G.R. No. L-79484
Decision Date
Dec 7, 1987
Foreign investors challenged PCGG's indefinite hold-order, citing violation of their constitutional right to travel and due process; Supreme Court ruled in their favor, lifting the order due to lack of justification and procedural lapses.
A

Case Summary (G.R. No. L-79484)

Background

The petitioners are foreign investors owning 33% of the shares in two sequestered domestic garment corporations, namely, De Soleil Apparel Manufacturing Corporation and American Inter-Fashion Manufacturing Corporation. The PCGG issued Hold-Orders against them, asserting their involvement in obstructing investigations into ill-gotten wealth related to the former Marcos regime. These orders prohibited the petitioners from leaving the Philippines.

Grounds for Petition

The petitioners contend that the Hold-Orders violate their constitutional right to travel, are unauthorized under applicable executive orders and PCGG regulations, and constitute harassment and a breach of due process. They further assert that the Orders have caused significant distress and hardship to themselves and their families.

PCGG's Opposition

The PCGG argued that the Hold-Orders were necessary to ensure the petitioners' presence for the resolution of ongoing corporate issues and to avoid obstructing operations and finances of the sequestered firms. The Commission claimed that the petitioners had engaged in actions detrimental to these companies, justifying the restriction.

Expiration of Hold-Orders

The Court found that the Hold-Orders had expired under the PCGG's own regulations, which dictate that such orders are valid for only six months unless extended for good cause. The PCGG did not extend the Hold-Orders, and no justifiable reasons were provided to continue them beyond the validity period.

Staleness of Grounds

The Court noted that the grounds for the Hold-Orders had become stale, given that the PCGG had appointed an Officer-in-Charge for the firms and had taken over their operation, resulting in improvements in management and profitability. The operational issues cited by the PCGG as a basis for the Hold-Orders no longer persisted.

Right to Due Process

The PCGG's failure to provide the petitioners with a fair opportunity to contest the Hold-Orders was highlighted as a violation of due process. No hearings were conducted to address the petitioners’ requests, nor were their motions given appropriate consideration, constituting a disregard for fairness as mandated by the PCGG's own executive order.

Fundamental Right to Travel

The Court emphasized that the right

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