American Inter-Fashion Corporation v. Office of the President, Garments & Textile Export Board & Glorious Sun Fashion Garments Manufacturing Co. (Phils.), Inc.
REVERSALFacts
The Antecedents: The Garments and Textile Export Board (GTEB) ruled on April 24, 1984, that Glorious Sun Fashion Garments Manufacturing Co. (Phils.), Inc. (Glorious Sun) was guilty of misdeclaration of imported raw materials, resulting in dollar salting abroad, and ordered the cancellation of its export quotas. These quotas were then allocated to two newly-formed corporations, De Soleil Apparel Manufacturing Corporation and American Inter-Fashion Corporation (AIFC), which were joint ventures involving Hongkong investors, majority stockholders of Glorious Sun, and allegedly a Marcos family member and crony. The Office of the President (OP) later set aside the GTEB decision and remanded the case for genuine hearings with due process. AIFC filed a motion for reconsideration of a Supreme Court resolution that had referred the issues to the Sandiganbayan. Procedural History: Glorious Sun initially filed a petition for certiorari and prohibition with the Supreme Court (G.R. No. 67180) in 1984, alleging violation of due process and lack of substantial evidence for the GTEB decision. The Court ordered GTEB to conduct further proceedings. However, Glorious Sun withdrew its petition, which was granted by the Court. More than two years later, Glorious Sun filed a petition with GTEB for restitution of its export quotas, alleging coercion by former Minister Roberto V. Ongpin to transfer quotas to crony-owned corporations and to withdraw its Supreme Court petition. GTEB denied this petition on September 4, 1987. Glorious Sun appealed to the OP (OP Case No. 3781). AIFC intervened, arguing the 1984 GTEB decision was final. On September 7, 1989, the OP ruled in favor of Glorious Sun, finding the 1984 GTEB proceedings irregular and remanding the case to GTEB for further proceedings. AIFC's motion for reconsideration was denied on February 20, 1990. The Supreme Court initially referred the issues to the Sandiganbayan but later set aside this resolution upon motion for reconsideration. The Petition: AIFC filed the instant petition, questioning the OP's decision and resolution, alleging grave abuse of discretion amounting to lack of jurisdiction for taking cognizance of Glorious Sun's appeal and for finding a violation of Glorious Sun's right to procedural due process.
Issue(s)
Whether the Sandiganbayan has exclusive and original jurisdiction over the instant petition. Whether the Office of the President committed grave abuse of discretion amounting to lack of jurisdiction in taking cognizance of Glorious Sun's appeal. Whether the Office of the President committed grave abuse of discretion amounting to lack of jurisdiction in finding that Glorious Sun's right to procedural due process was violated by the GTEB in 1984.
Ruling
The Supreme Court granted the motion for reconsideration, set aside its previous resolution referring the case to the Sandiganbayan, and affirmed the questioned decision and resolution of the Office of the President. The petition was dismissed.
Ratio Decidendi
On the jurisdiction of the Sandiganbayan: The Court reiterated that the Sandiganbayan's exclusive and original jurisdiction, as defined by Executive Order No. 14, pertains to cases concerning funds, moneys, assets, and properties illegally acquired or misappropriated by former President Ferdinand Marcos and his associates. This jurisdiction extends to all incidents arising from, incidental to, or related to such cases. However, the instant case, which arose from a 1984 GTEB ruling on misdeclaration of importations and cancellation of export quotas, is a principal case and not an incident of any sequestration or ill-gotten wealth case. The Sandiganbayan does not have jurisdiction to ascertain whether the Office of the President's decision reviewing the GTEB ruling suffers from grave abuse of discretion, as this power rests with the Supreme Court under Rule 65. On the Office of the President's cognizance of the appeal: The Court found that the GTEB's 1984 decision canceling Glorious Sun's export quotas was not a final judgment on the merits that would constitute res judicata. The prior Supreme Court case (G.R. No. 67180) was dismissed based on a motion for withdrawal, not an adjudication of the issues. Therefore, the Office of the President did not err in taking cognizance of Glorious Sun's appeal, as the issues had not been joined and the merits had not been determined. On the violation of due process: The Court affirmed the Office of the President's finding that Glorious Sun was denied due process in the 1984 GTEB proceedings. The petitioner itself admitted that GTEB failed to disclose vital evidence used in its conclusion. The subsequent disclosure of documents in 1987 did not cure the defect of non-disclosure in 1984, as the original resolution was based on undisclosed evidence. Furthermore, the data presented by GTEB to justify the cancellation was found to be selectively chosen and not comparable due to differing specifications and terms (FOB vs. C&F vs. CIF), as indicated by GTEB's own Raw Materials Importation Regulation Division. The affidavit of Rodolfo Puno, Chairman of the investigating panel, also cast doubt on the fairness of the 1984 proceedings, suggesting pressure from Minister Ongpin to find Glorious Sun guilty even without sufficient evidence. The cancellation of export quotas, which had become akin to property rights, without due process was therefore improper.
Main Doctrine
The Sandiganbayan's exclusive and original jurisdiction extends only to cases involving ill-gotten wealth and related incidents, not to administrative decisions of agencies like the GTEB or the propriety of the Office of the President's review of such decisions, unless these are directly incidental to ill-gotten wealth cases. The Supreme Court, through a petition for certiorari under Rule 65, is the proper tribunal to review alleged grave abuse of discretion by the Office of the President.