Case Summary (G.R. No. 93173)
Transaction Background
On July 2, 1987, the owners of PPI, including Ramos, sold their shares to Saavedra for P1.2 million in installments, documented through a Memorandum of Agreement and a Deed of Assignment. These agreements included an automatic rescission clause if any payment was missed. Saavedra paid a total of P936,380.00, with a remaining balance of P263,620.00 due on September 15, 1987. Saavedra withheld this payment due to the sellers' alleged failure to honor warranties, but he deposited the amount in escrow contingent upon warranty compliance.
Legal Proceedings Initiated
On November 5, 1987, while a civil complaint for damages was pending against Ramos in the SEC, Ramos filed a criminal case for perjury against Saavedra, claiming he falsely stated he was President of PPI in the complaint he filed. The Provincial Prosecutor later determined that a prima facie case for perjury existed based on a Secretary's Certificate showing Ramos had been elected President after the alleged automatic rescission of the agreement.
Department of Justice Review
Saavedra sought a review from the DOJ regarding the Provincial Prosecutor’s Resolution, which found probable cause for perjury. The DOJ upheld this finding, stating that Saavedra's assertion of being PPI's President was legally and intentionally false due to the rescission of the agreements.
Petitioner's Argument
In his petition to the Supreme Court, Saavedra contested the DOJ's findings, asserting that the questions of ownership and rescission were within the jurisdiction of the SEC, and that the DOJ had overstepped its authority by making determinations on those matters. He highlighted that the jurisdiction of these issues rested with the SEC, which had already been established in earlier relevant jurisprudence.
Legal Principles Applied
The Supreme Court reiterated the doctrine of primary jurisdiction, which requires courts to defer to the specialized knowledge and competence of administrative bodies for matters within their purview. The SEC, as the regulatory body, holds exclusive authority over intracorporate disputes, including issues of ownership and automatic rescission.
Decision on the Perjury Charge
The Court found that the Provincial Prosecutor acted beyond its jurisdiction by proceeding with the perjury case when the fundamental questions surrounding the automatic rescission and the legitimacy of Saavedra’s claims were unresolved a
...continue readingCase Syllabus (G.R. No. 93173)
Case Overview
- This case involves a petition for certiorari and prohibition filed by Honorio Saavedra, Jr. against the Department of Justice (DOJ) and others.
- The petition seeks to nullify the DOJ Resolution dated November 6, 1989, which dismissed Saavedra's Petition for Review of the Provincial Prosecutor's Resolution that found probable cause for perjury against him.
- The case also contests the DOJ Resolution dated March 7, 1990, which denied Saavedra's motion for reconsideration.
Factual Background
- On July 2, 1987, the owners of Pine Philippines, Inc. (PPI), including private respondent Gregorio M. Ramos, sold their shares to petitioner Saavedra for P1.2 million, payable in installments.
- A "Memorandum of Agreement" and a "Deed of Assignment" were executed, including an automatic rescission clause for unpaid installments.
- Saavedra paid a total of P936,380.00 but withheld the remaining P263,620.00 due on September 15, 1987, citing non-compliance with warranties by the sellers.
- The remaining amount was deposited in escrow pending compliance with the warranties.
Legal Proceedings Initiated
- On November 5, 1987, Saavedra filed a verified civil complaint for damages against Ramos, asserting he was the President and principal stockholder of PPI.
- Ramos contested Saavedra's capacity to sue, claiming the sale was automatically rescinded due to non-payment.
- Subsequently, Ramos filed a case with the Securities and Exchange Commission (SEC) to declare the rescission valid.
- Saavedra challenged the SEC's jurisdiction, but the Sup