Y Realty Corporation v. Honorable Sandiganbayan
REITERATIONFacts
The Antecedents: The Republic of the Philippines filed a complaint for rescission, reconveyance, restitution, accounting, and damages against Ferdinand E. Marcos, Imelda Marcos, and Prime Holdings, Inc. (PHI) before the Sandiganbayan. Alfonso Yuchengco filed a complaint-in-intervention, claiming ownership of the properties sought to be forfeited. The Sandiganbayan granted his motion to intervene. Subsequently, Yuchengco filed an amended complaint-in-intervention to implead Imelda Cojuangco and the Estate of Ramon U. Cojuangco, who claimed ownership of PHI. The Cojuangcos moved to dismiss the amended complaint-in-intervention, citing failure to state a cause of action and lack of jurisdiction due to non-payment of correct docket fees, referencing the doctrine in Manchester Development Corporation, et al. v. Court of Appeals. Yuchengco contended that proceedings before the Sandiganbayan are free of charge pursuant to Section 11 of Presidential Decree No. 1606, as amended. Procedural History: Yuchengco later filed a second amended complaint-in-intervention, seeking to include Y Realty Corporation as co-plaintiff and Imelda R. Marcos as representative of the Estate of Ferdinand Marcos. PHI and the Cojuangcos opposed this motion, arguing that jurisdictional issues, particularly the docket fees, should be resolved first. Yuchengco moved for early resolution and proposed to post a bond to answer for any docket fees, praying that the prescriptive period be tolled. The Sandiganbayan deferred the resolution of the motion to dismiss until trial. Later, the Sandiganbayan denied Yuchengco's motion to post bond and ordered him to pay the balance of the docket fee, which he paid with reservation. PHI and the Cojuangcos moved for reconsideration, arguing that the docket fees should be based on the stated value of the shares in Philippine Telecommunications Investment Corporation (PTIC), amounting to P1.6 billion, and that Yuchengco should pay P5,391,154.35. The Sandiganbayan denied this motion. Subsequently, the Sandiganbayan issued a Resolution dated October 9, 1996, granting the motion to dismiss and denying the motion to admit the second amended complaint-in-intervention. A motion for reconsideration was denied on October 6, 1997. The Petition: Y Realty Corporation, having identical interests with Alfonso Yuchengco and with Yuchengco as its majority stockholder, filed the present petition for certiorari, assailing the Sandiganbayan's Resolutions dated October 9, 1996, and October 6, 1997. The dismissal of Yuchengco's amended complaint-in-intervention led to the denial of the joint motion to admit the second amended complaint-in-intervention filed by Yuchengco and Y Realty.
Issue(s)
Whether the Sandiganbayan gravely abused its discretion in dismissing Alfonso Yuchengco's amended complaint-in-intervention and denying the motion to admit the second amended complaint-in-intervention filed by Yuchengco and Y Realty Corporation. Whether the Sandiganbayan gravely abused its discretion in dismissing the amended complaint-in-intervention for failure to pay the correct docket fees on time, and whether the running of the prescriptive period was tolled due to the Sandiganbayan's prolonged inaction on the issue of docket fees. On the procedural status of Y Realty Corporation.
Ruling
The petition is GRANTED. The Sandiganbayan is directed to resolve with dispatch, upon payment of the correct docket fee mandated by this Court in G.R. No. 131127, the motion to admit the second amended complaint-in-intervention filed by Yuchengco and petitioner Y Realty. No costs.
Ratio Decidendi
On the dismissal of the amended complaint-in-intervention: The Court set aside the Sandiganbayan's Resolutions dismissing Yuchengco's amended complaint-in-intervention. This reinstatement of Yuchengco's complaint, upon payment of the correct docket fee, removes any procedural obstacle for the Sandiganbayan to rule on the joint motion to admit the second amended complaint-in-intervention filed by Yuchengco and Y Realty Corporation. The Court directed the Sandiganbayan to act with dispatch on the matter once the correct docket fee is determined and paid. On the issue of docket fees and prescription: The Court reiterated its ruling in G.R. No. 131127, holding that Alfonso Yuchengco was not barred from asserting his causes of action due to non-payment of proper docket fees. The Court emphasized that Yuchengco did not sleep on his rights and actively pursued the resolution of the docket fee issue by seeking early resolution and proposing to post a bond. The prolonged inaction of the Sandiganbayan on this pivotal issue was considered a supervening event beyond Yuchengco's control, which tolled the running of the prescriptive period. Punishing Yuchengco for the Sandiganbayan's delay would set a bad precedent and give trial courts an unfair weapon to frustrate the filing of actions. The Court stressed that while parties filing civil actions before the Sandiganbayan are now liable to pay docket fees, Yuchengco acted in good faith in contending that proceedings were free of charge, especially given his reservation for payments made after being ordered to pay. The Court clarified that the situation in the case at bar was unique due to Yuchengco's honest conviction and the Sandiganbayan's delayed action. On the procedural status of Y Realty Corporation: The Court acknowledged that Y Realty Corporation could not join Yuchengco in his petition in G.R. No. 131127 because, at the time the Sandiganbayan's challenged Resolutions were issued, Y Realty was not yet a formal party to Civil Case No. 0002. Its motion to intervene as a co-plaintiff was still pending resolution. The dismissal of Yuchengco's complaint-in-intervention consequently led to the denial of the joint motion to admit the second amended complaint-in-intervention filed by Yuchengco and Y Realty. Therefore, by granting Yuchengco's petition and ordering the reinstatement of his complaint, the procedural impediment for Y Realty's intervention is removed.
Main Doctrine
The Supreme Court reiterated that while parties filing civil actions before the Sandiganbayan are liable to pay the required docket fees, the belated action of the Sandiganbayan on the issue of docket fees, after prolonged inaction, constitutes a supervening event that tolls the running of the prescriptive period. The Court also directed the Sandiganbayan to resolve with dispatch the motion to admit the second amended complaint-in-intervention upon payment of the correct docket fee.