Case Summary (G.R. No. 141796)
Antecedent Facts
Following the revolution on February 25, 1986, Executive Order No. 1 was issued to assist in the recovery of ill-gotten wealth accumulated by the Marcos regime. Jose Y. Campos, recognized as a crony of Marcos, surrendered properties and corporations, including Independent Realty Corporation (IRC) and Mid-Pasig Land Development Corporation (MLDC), to the PCGG. Subsequently, the Republic of the Philippines, through the PCGG and the Solicitor General, filed a civil complaint in the Sandiganbayan for reconveyance of properties and damages, listing various defendants, including Ilusorio.
Allegations of Conspiracy and Ill-Gotten Wealth
The complaint contends that the listed defendants, including Ilusorio, acted as dummies or agents of the Marcoses and engaged in this conduct to secure substantial ill-gotten wealth. It alleges that they manipulated shareholdings in companies, thereby acquiring wealth in violation of public trust. The Republic sought the reconveyance of these assets, leading to a trial where claims regarding the nature of ownership of assets, including stocks from the Philippine Overseas Telecommunications Corporation (POTC), were heavily disputed.
Respondent's Position
In his amended answer, Ilusorio rejected allegations of conspiracy and asserted that he legitimately owned 5,400 POTC shares, which were wrongfully taken by the Marcoses through intimidation. He sought to reclaim not only the shares but also the corresponding dividends, positioning himself as a victim amidst the political machinations of his co-defendants.
Compromise Agreement
The case progressed with a significant development when a Compromise Agreement was reached between the PCGG and Ilusorio on June 28, 1996. This agreement was intended as a final settlement of claims and facilitated the amicable resolution of the whole matter. It stipulated the rights and ownership of shares between the parties, wherein Ilusorio acknowledged the Republic's claim over 4,727 POTC shares while retaining 673 shares for himself. The agreement required court approval, which was granted by the Sandiganbayan in a subsequent order on June 8, 1998.
Motions to Vacate the Compromise Agreement
Subsequent to the approval of the Compromise Agreement, MLDC and IRC filed motions to vacate the Sandiganbayan’s order, claiming they were not parties to the agreement and that its terms were disadvantageous. Notably, the PCGG expressed agreement with this motion, contending that the absence of a formal resolution authorizing the compromise rendered it invalid.
Sandiganbayan’s December 20, 1999 Resolution
In its resolution dated December 20, 1999, the Sandiganbayan denied the petitions to vacate the Compromise Agreement. The court held that the agreement was valid and executory, supported by the arguments that the PCGG had the authority to act on behalf of the petitioner and that no legal standing existed for MLDC due to its default status in prior proceedings.
Jurisprudential Principle and Procedural Norms
The decision emphasize
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Case Overview
- This case involves two consolidated petitions for certiorari filed with the Supreme Court challenging the Sandiganbayan's Resolution dated December 20, 1999.
- The petitions contest the resolution's denial of the petitioners' motions to vacate an earlier order approving a Compromise Agreement between the Presidential Commission on Good Government (PCGG) and Potenciano Ilusorio.
- The case is rooted in the efforts to recover ill-gotten wealth associated with former President Ferdinand E. Marcos and his associates.
Background of the Case
- Following the EDSA People Power Revolution in February 1986, President Corazon C. Aquino established the PCGG through Executive Order No. 1.
- The PCGG's mandate includes recovering ill-gotten wealth amassed by Ferdinand E. Marcos, his family, and associates.
- Jose Y. Campos, a former crony of Marcos, surrendered properties and businesses, including the Independent Realty Corporation (IRC) and the Mid-Pasig Land Development Corporation (MLDC), to the PCGG.
Initial Complaint and Key Allegations
- In July 1987, the Republic filed a complaint against several individuals, including Ilusorio, for reconveyance, reversion, accounting, restitution, and damages, citing collusion among defendants to acquire ill-gotten wealth.
- The complaint alleged that defendants acted as dummies and nominees for Marcos, resulting in substantial illegal gains, specifically regarding shareholdings in the Philippine Overseas Telecommunications Corporation (POTC).
Ilusorio's Response
- Respondent Potenciano Ilusorio denied all