Presidential Commission on Good Government v. Peña
REITERATIONFacts
The Antecedents: The Presidential Commission on Good Government (PCGG) issued an order freezing the assets of American Inter-fashion Corporation and De Soleil Apparel Manufacturing Corporation. The PCGG appointed an Officer-in-Charge (OIC) to manage these corporations and designated authorized signatories for their bank accounts. A dispute arose when the OIC revoked the authorization of one signatory, Mr. Yim Kam Shing, and appointed new ones. Subsequently, the OIC withdrew P400,000.00 from the corporations' accounts for salaries. Procedural History: Respondents Yeung Chun Kam, Yeung Chun Ho, and Archie Chan, through Yim Kam Shing, filed an action for damages with a prayer for a writ of preliminary injunction against the bank, the PCGG, Commissioner Mary Concepcion Bautista, and the OIC. They questioned the revocation of Mr. Yim Kam Shing's signatory authority. The Regional Trial Court (RTC), presided by respondent Judge Emmanuel G. Peña, issued an ex-parte temporary restraining order enjoining the bank from releasing funds without Mr. Yim Kam Shing's signature and restraining the PCGG from enforcing its memorandum revoking the authorization. The PCGG filed a motion to dismiss, arguing lack of jurisdiction and grave abuse of discretion. The RTC denied the motion to dismiss and granted the preliminary injunction. The Petition: The PCGG filed a special civil action for certiorari, prohibition, and mandamus with preliminary injunction and/or restraining order, seeking to set aside the RTC's orders on grounds of lack of jurisdiction and grave abuse of discretion. The core issue was whether RTCs have jurisdiction over the PCGG and sequestered properties, and if they can interfere with the PCGG's actions.
Issue(s)
Whether regional trial courts have jurisdiction over the Presidential Commission on Good Government (PCGG) and properties sequestered by it. Whether regional trial courts may interfere with and restrain or set aside the orders and actions of the PCGG. Whether the RTC committed grave abuse of discretion in issuing the temporary restraining order and preliminary injunction.
Ruling
The Supreme Court granted the petition, setting aside the orders of the respondent judge dated February 16 and March 5, 1987, and ordering the dismissal of Civil Case No. 54298. The decision was declared immediately executory.
Ratio Decidendi
On the jurisdiction of Regional Trial Courts over the PCGG and sequestered properties: The Court held that regional trial courts (RTCs) 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. Section 2 of Executive Order No. 14 explicitly vests the exclusive and original jurisdiction over all cases concerning ill-gotten wealth, assets, and properties in the Sandiganbayan. Consequently, all incidents arising from, incidental to, or related to such cases also fall under the exclusive and original jurisdiction of the Sandiganbayan. The Court emphasized that the Sandiganbayan's decisions are subject to review on certiorari exclusively by the Supreme Court, thereby precluding interference from lower courts. This exclusivity is rooted in the need to efficiently recover ill-gotten wealth amassed by the previous regime, preventing the Commission's task from being impeded by numerous suits in inferior courts. On the power of RTCs to interfere with PCGG actions: The Court ruled that RTCs cannot interfere with, restrain, or set aside the orders and actions of the PCGG. The PCGG exercises quasi-judicial functions, making it a co-equal body with RTCs, and co-equal bodies cannot control each other. Furthermore, Section 4(a) of Executive Order No. 1 grants the PCGG and its members immunity from suit for damages for acts done in the discharge of their tasks. This immunity effectively withholds jurisdiction over cases against the PCGG from all lower courts, except the Sandiganbayan and the Supreme Court. The Court stressed that public policy dictates that the PCGG should not be bogged down by legal suits before inferior courts, as this would defeat the purpose of its creation. On the RTC's alleged grave abuse of discretion: The respondent judge's issuance of the temporary restraining order and preliminary injunction was deemed an act without jurisdiction and thus a grave abuse of discretion. By entertaining a case over which it had no jurisdiction, the RTC overstepped its authority. The Court reiterated that questions and disputes seeking to controvert the PCGG's findings or challenge its orders must be brought before the Sandiganbayan, which has exclusive and original jurisdiction. The administrative remedies provided by the PCGG for contesting sequestration orders must be exhausted before resorting to judicial action. The Court's power of certiorari is reserved for reviewing alleged violations of constitutional and legal rights, not for supervising co-equal bodies.
Main Doctrine
Regional Trial Courts do not have jurisdiction over the Presidential Commission on Good Government (PCGG) and properties sequestered by it in the exercise of its powers under Executive Orders Nos. 1, 2, and 14, as amended. All cases involving ill-gotten wealth, assets, and properties fall under the exclusive and original jurisdiction of the Sandiganbayan, subject to review exclusively by the Supreme Court.