Chavez v. Presidential Commission on Good Government
REITERATIONFacts
The Antecedents: Movants Ma. Imelda Marcos-Manotoc, Ferdinand R. Marcos II, and Irene Marcos-Araneta sought to intervene in the case, alleging they were parties and signatories to the General and Supplemental Agreements dated December 28, 1993. This Court, in its December 9, 1998 Decision, had declared these agreements "NULL AND VOID for being contrary to law and the Constitution." Movants claimed their exclusion denied them due process and equal protection, and questioned the Court's cognizance of the petition based on the principle of hierarchical administration of justice. Procedural History: The Supreme Court promulgated its Decision on December 9, 1998, declaring the Agreements null and void. Movants filed their Motion for Leave to Intervene and Partial Motion for Reconsideration on January 22, 1999, and their Memorandum of Authorities on March 16, 1999. The Petition: The original petition was filed by Francisco I. Chavez, seeking to enforce a constitutional right against the Presidential Commission on Good Government (PCGG) and to determine if the latter was acting within its authority. The petition involved constitutional and legal questions concerning public interest.
Issue(s)
Whether intervention can be allowed after a judgment has become final and executory. Whether the movants were denied due process and equal protection. Whether the Supreme Court erred in taking primary jurisdiction over the case, bypassing the principle of hierarchical administration of justice. Whether the petition was rendered moot and academic by the public disclosure of the agreements. Whether the alleged partial implementation of the agreements constituted ratification.
Ruling
The motions are DENIED for lack of merit. The Decision of December 9, 1998, is ordered to be entered.
Ratio Decidendi
On the timeliness of intervention: The Court ruled that intervention cannot be allowed after a judgment has become final and executory. Section 2, Rule 19 of the Rules of Court mandates that a motion to intervene should be filed "before rendition of judgment." Since the Decision was promulgated on December 9, 1998, and the movants filed their motion on January 22, 1999, their intervention was filed at a "late stage of the proceedings" and in a case already "terminated by the final judgment." Furthermore, the movants failed to offer any "valid plausible excuse" for their delayed action, especially considering the "well-publicized" nature of the original petition and its proceedings. On the denial of due process and equal protection: The Court held that the movants were merely "incidental, not indispensable, parties" to the case. While they were contractors to the Agreements, the Court found that these agreements contained terms and conditions "clearly contrary to the Constitution and the laws" and were thus "null and void ab intio." Such void agreements "vest no rights and create no obligations" and "produce no legal effect at all." Therefore, the movants had "no interest to protect or right to assert in this proceeding," and no "infraction upon their rights" had been committed. The Court also noted that by ruling on the merits of their arguments, it had effectively given them a hearing, precluding any complaint of not having been heard. On the hierarchy of courts: The Court reiterated that the principle of the hierarchy of courts generally applies to cases involving factual questions, not constitutional and legal questions of public interest. In this instance, the Court resolved to exercise primary jurisdiction to avoid "unnecessary delays and expenses" and to promote "substantial justice." The Court emphasized its discretion to "suspend procedural rules" when warranted. By taking jurisdiction, the Court facilitated a more speedy resolution of the ill-gotten wealth cases. On the petition being moot and academic: The Court clarified that the petition was not confined to the concluded terms of the Agreements but also concerned "other ongoing and future negotiations and agreement, perfected or not." It sought a "precise interpretation of the scope of the twin constitutional provisions on 'public transactions'" and was therefore not rendered moot by the public disclosure of the Agreements. On alleged partial implementation: The Court stated that the subject Agreements were "null and void for being contrary to the Constitution and the laws." As such, they were "not subject to ratification" and would "neither acquire validity through the passage of time." Therefore, any alleged partial implementation was "immaterial."
Main Doctrine
Intervention cannot be allowed after a judgment has become final and executory. Moreover, parties whose rights are merely incidental and not indispensable to the case, and whose claims involve agreements that are null and void for being contrary to law and the Constitution, cannot assert any valid interest in the proceeding. The Supreme Court may take primary jurisdiction over cases involving constitutional and legal questions of public interest, even if it deviates from the principle of hierarchical administration of justice, to avoid unnecessary delays and promote substantial justice.