Soriano v. Yuzon
REITERATIONFacts
The Antecedents: Several petitions arose from the sale of San Miguel Corporation (SMC) shares by 14 companies to Andres Soriano III. The sale agreement stipulated a price and payment terms, with a provision for automatic reversion of ownership upon default. The shares were sequestered by the Presidential Commission on Good Government (PCGG) on the theory that they belonged to Eduardo Cojuangco, Jr., allegedly a dummy of former President Ferdinand Marcos, and that the sale contravened Executive Orders prohibiting the transfer of assets acquired as ill-gotten wealth. The sequestration was initially lifted but later reimposed. The PCGG directed SMC not to consider the sequestered shares in determining quorum and voting at stockholders' meetings, and later announced its intention to vote them. The PCGG also directed the registration of qualifying shares in the name of its nominees to enable them to qualify as directors, which resulted in their election at the June 4, 1986 meeting. Procedural History: Contentious proceedings arose in the Securities and Exchange Commission (SEC) and Regional Trial Courts (RTC). In the SEC, cases were filed questioning the sale agreement, the stockholders' meeting, and the sequestration of SMC and United Coconut Planters Bank (UCPB) shares. The SEC denied motions to dismiss based on the PCGG's alleged primary jurisdiction, asserting its own jurisdiction over intracorporate disputes. In the RTC, cases were filed seeking rescission of the sale agreement and challenging the issuance of restraining orders, with defendants arguing that the RTC lacked jurisdiction due to the PCGG's sequestration. The RTC denied injunctions, ruling on ownership claims. The Petition: Aggrieved parties from the SEC and RTC orders filed petitions with the Supreme Court, seeking annulment or inhibition of the orders and proceedings. These petitions raised issues concerning the basis for sequestration, the jurisdiction of the RTC and SEC over sequestered properties and ownership disputes, and the validity of PCGG actions.
Issue(s)
Whether there is a factual and legal basis for the sequestration of the SMC and UCPB shares. Whether the validity of the sequestration is cognizable by the Regional Trial Court and the Securities and Exchange Commission. Whether disputes involving the ownership of the sequestered shares are cognizable by the Regional Trial Court and the Securities and Exchange Commission.
Ruling
The Supreme Court dismissed all the actions at bar and directed the dismissal of the cases pending before the Regional Trial Court and the Securities and Exchange Commission. This dismissal is without prejudice to the assertion and ventilation of respective claims before the Sandiganbayan. The temporary restraining order issued on June 30, 1987, was lifted and set aside.
Ratio Decidendi
On the sequestration of SMC and UCPB shares: The Court reiterated its ruling in Presidential Commission on Good Government vs. Hon. Emmanuel G. Peña et al., G.R. No. 77663, April 12, 1988, holding that regional trial courts and the Court of Appeals lack jurisdiction over the PCGG's powers under applicable Executive Orders and the Constitution. Consequently, they may not interfere with or restrain or set aside the orders and actions of the PCGG. This exclusivity extends not only to the principal causes of action for the recovery of ill-gotten wealth but also to all incidents arising from, incidental to, or related to such cases. The rationale is the necessity of concentrating such cases in a specialized court to facilitate the recovery of plundered wealth. On the cognizability of sequestration validity by RTC and SEC: Given the exclusive jurisdiction vested in the Sandiganbayan, the Regional Trial Courts and the Securities and Exchange Commission are divested of jurisdiction to hear and decide cases involving the validity of sequestration orders issued by the PCGG. These matters are considered incidents arising from or related to the PCGG's primary task of recovering ill-gotten wealth, which falls squarely within the Sandiganbayan's original and exclusive jurisdiction. Any attempt by lower courts or administrative bodies to pass upon these issues would constitute an encroachment upon the Sandiganbayan's authority. On the cognizability of ownership disputes by RTC and SEC and dismissal of pending cases: Given the exclusive jurisdiction vested in the Sandiganbayan, the Regional Trial Courts and the Securities and Exchange Commission are divested of jurisdiction to hear and decide disputes over the ownership of sequestered shares. In light of the exclusive jurisdiction of the Sandiganbayan, all the cases pending before the RTC and the SEC, which involved the validity of sequestration and ownership disputes of the subject shares, were dismissed without prejudice to the parties asserting their claims in the appropriate forum, the Sandiganbayan, through prescribed legal modes. The Supreme Court emphasized that it is not a trier of facts and that the conflicting claims regarding the ownership of the sequestered stock must be litigated before the Sandiganbayan.
Main Doctrine
Regional trial courts and the Court of Appeals have no jurisdiction over the Presidential Commission on Good Government (PCGG) in the exercise of its powers under applicable Executive Orders and the Constitution. All cases involving the recovery of ill-gotten wealth, and all incidents arising from, incidental to, or related to such cases, are lodged within the exclusive and original jurisdiction of the Sandiganbayan, subject to review on certiorari exclusively by the Supreme Court.