Republic v. Sandiganbayan
REITERATIONFacts
The Antecedents: On July 21, 1987, the Presidential Commission on Good Government (PCGG) filed a complaint for reconveyance, reversion, accounting, restitution, and damages against Bienvenido R. Tantoco, Jr., Dominador R. Santiago, and the Marcoses (Civil Case No. 0008) before the Sandiganbayan. The defendants initially filed a motion for a bill of particulars, which led the PCGG to file an Expanded Complaint. Subsequently, the defendants sought to serve interrogatories and move for the production of documents to clarify the specific acts and properties involved in the allegations of 'ill-gotten wealth.' Procedural History: The Sandiganbayan initially denied the defendants' motion for leave to file interrogatories as premature since no answer had been filed. After the defendants filed their Answer with Compulsory Counterclaim, they served 'Amended Interrogatories to Plaintiff' and a 'Motion for Production and Inspection of Documents.' The PCGG opposed these, arguing that the interrogatories were non-specific, sought evidentiary matters already denied in the bill of particulars, and that the documents were privileged under Executive Order No. 1. On September 29, 1989, the Sandiganbayan issued resolutions admitting the interrogatories and granting the motion for production. The Petition: The PCGG filed a petition for certiorari under Rule 65, asserting that the Sandiganbayan committed grave abuse of discretion. The PCGG argued that the interrogatories were addressed to the commission generally rather than specific individuals, that the matters sought were evidentiary and intended for trial, and that its commissioners were immune from being required to testify or produce evidence under the immunity provisions of Executive Order No. 1 and Executive Order No. 14.
Issue(s)
Whether the interrogatories were defective for failing to name specific individuals and for seeking evidentiary matters. Whether the PCGG and its officers are immune from the modes of discovery under Executive Order No. 1. Whether the 'fishing expedition' argument is a valid ground to block discovery.
Ruling
The petition is DENIED. The temporary restraining order is LIFTED and SET ASIDE.
Ratio Decidendi
On Issue 1: The Court ruled that the interrogatories were not defective. Under Section 1, Rule 25, if the party served is a juridical entity like a public corporation, the interrogatories shall be answered by any officer competent to testify on its behalf; thus, naming a specific individual is unnecessary. Furthermore, the Court distinguished between a bill of particulars and discovery: while a bill of particulars is limited to clarifying 'ultimate facts' in a pleading, discovery is specifically designed to allow inquiry into 'evidentiary facts.' The fact that the Sandiganbayan previously denied a bill of particulars on these matters does not preclude the use of interrogatories to extract the same information as evidence. The obligation to answer subsists unless a specific objection regarding relevancy or bad faith is sustained. On Issue 2: The Court held that the PCGG cannot invoke immunity to avoid discovery in a case it initiated. While the State is generally immune from suit, it divests itself of its sovereign character and descends to the level of an ordinary litigant when it files a civil action. The immunity provided in Executive Order No. 1, which protects PCGG members from civil actions for acts done in the discharge of their duties, does not apply to the procedural requirements of a lawsuit the PCGG itself commenced. By bringing suit, the PCGG implicitly waives the exemption from giving evidence and must 'disgorge' all relevant facts in its possession. It would be absurd to allow the PCGG to require defendants to disclose facts while remaining exempt from the same compulsion. On Issue 3: The Court explicitly stated that 'fishing expeditions' are permitted under the modern rules of discovery. The time-honored cry of 'fishing expedition' no longer serves to preclude a party from inquiring into the facts underlying an opponent's case. Mutual knowledge of all relevant facts gathered by both parties is essential to proper litigation, and discovery simply advances the stage at which disclosure can be compelled from the time of trial to the period preceding it. This reduces the possibility of surprise and allows for a more intelligent and adequate preparation for trial. The liberal treatment of discovery modes is intended to ensure that the 'cards are on the table' before the trial begins.
Main Doctrine
The modes of discovery (Rules 24 to 29 of the Rules of Court) are intended to be accorded a broad and liberal treatment to ensure that civil trials are not carried on in the dark. Their purpose is to narrow and clarify basic issues and to ascertain facts relative to those issues before the trial begins. By taking the initiative in an action against private parties, the State surrenders its privileged position and comes down to the level of the defendant, thereby becoming subject to the same rules of discovery applicable to private litigants. The 'fishing expedition' objection is no longer a valid ground to preclude a party from inquiring into the facts underlying an opponent's case.