Case Summary (G.R. No. 230391)
Applicable Law and Procedures
The petitions are governed by the 1987 Philippine Constitution and Rules of Court, particularly under Rule 65 for petitions for certiorari and Rule 45 for petitions for review on certiorari. The Court's rulings were influenced by existing jurisprudence regarding the execution of judgments pending appeal, particularly concerning grave abuse of discretion.
Procedural Background
In G.R. No. 230391, Romualdez sought to nullify the Court of Appeals’ resolutions that allowed execution pending appeal of the Regional Trial Court's orders, which had granted FPHC’s petition to perpetuate her testimony. In G.R. No. 250746, Romualdez challenged the Court of Appeals' affirmation of these orders.
Historical Context of Ownership Disputes
FPHC was the former owner of over six million shares in PCIB, sold to Trans Middle East (Phils.) Equities, Inc. (TMEE). These shares were sequestered by the PCGG in 1986, deemed ill-gotten from Romualdez. The ensuing litigation over these shares involved numerous complaints and motions, highlighting the complexity and duration of the legal battles surrounding the ownership of the PCIB shares.
Rulings of the Regional Trial Court
The Makati Regional Trial Court, in its orders of April 2015, permitted the perpetuation of Romualdez's testimony, asserting that her advanced age justified it to prevent any delay or failure of justice. The court noted the absence of objection from the PCGG, which later informed the court that it did not oppose the deposition process.
Court of Appeals' Support for Execution Pending Appeal
The Court of Appeals granted FPHC's urgent motion for execution pending appeal, determining that Romualdez's deteriorating physical condition constituted a valid reason. The appellate court's reasoning emphasized the potential for a failure of justice if her testimony was not taken promptly, citing concerns over her age and health.
Supreme Court's Ruling on Appeals
The Supreme Court concluded that both of Romualdez's petitions were meritorious, identifying grave abuse of discretion in the Court of Appeals’ allowance for execution pending appeal. The Court emphasized that such actions are exceptions and require compelling reasons that were not sufficiently substantiated in this case.
Evaluation of Execution Pending Appeal
The Supreme Court highlighted that execution pending appeal should primarily be reserved for situations where urgent circumstances exist, which could outweigh potential damages to the opposing party if a reversal occurs. It found that the Court of Appeals did not adequately consider the dismissal of FPHC's intervention complaints, which called into question the urgency claimed.
Jurisdictional and Merit Considerations
The Supreme Court also addressed issues surrounding jurisdiction, ev
...continue readingCase Syllabus (G.R. No. 230391)
Overview of the Case
- Petitioners and Respondents: Juliette Gomez Romualdez (petitioner) vs. The Court of Appeals (CA), First Philippine Holdings Corporation (FPHC), and Presidential Commission on Good Government (PCGG).
- Case Numbers: G.R. No. 230391 and G.R. No. 250746.
- Court's Decision Date: July 5, 2023.
- Nature of the Petitions:
- G.R. No. 230391: Petition for Certiorari under Rule 65, seeking to nullify CA Resolutions dated September 20, 2016, and February 27, 2017.
- G.R. No. 250746: Petition for Review on Certiorari under Rule 45, seeking to reverse CA Decision dated September 4, 2019, and Resolution dated December 4, 2019.
Antecedents of the Case
- Background:
- FPHC was the former owner of 6,299,177 shares in Philippine Commercial and Industrial Bank (PCIB shares).
- These shares were sold to Trans Middle East (Phils.) Equities, Inc. (TMEE), and were later sequestered by the PCGG in 1986, deeming them ill-gotten wealth of Benjamin "Koko" Romualdez, petitioner’s husband.
- The PCGG filed a complaint for reconveyance and related claims against petitioner and Benjamin in the Sandiganbayan (Civil Case No. 0035).
- Prior Proceedings:
- FPHC filed motions in the Sandiganbayan to intervene and annul the sale to TMEE, which were dismissed on grounds of prescription.
- FPHC subsequently filed a petition to perpetuate the testimony of Juliette, claiming her testimony was crucial due to her personal knowledge of the acquisition of the shares.
Ruling of the Regional Trial Court (RTC)
- Order Date: April 27, 2015.
- Decision: The RTC granted FPHC's petition to perpetuate testimony, stat