Republic v. Sandiganbayan
REITERATIONFacts
The Antecedents: The underlying dispute concerns the ownership of shares in Piedras Petroleum Co., Inc. The Presidential Commission on Good Government (PCGG) sequestered shares held by seven individuals, including Rodolfo T. Arambulo, who were directors and subscribers of Piedras. The PCGG, representing the Republic of the Philippines, filed a case against Roberto S. Benedicto, Ferdinand E. Marcos, Imelda R. Marcos, and others, alleging the accumulation of ill-gotten wealth. While the main complaint focused on other assets and corporations, Arambulo was implicated in the establishment of the California Overseas Bank. The PCGG alleged that Imelda R. Marcos funded the subscriptions for Piedras shares through a specific bank check. Procedural History: The PCGG sequestered Arambulo's Piedras shares on July 23, 1987, and filed a civil case shortly thereafter. A Compromise Agreement was later entered into between the Republic and Roberto S. Benedicto, which was approved by the Sandiganbayan and affirmed by the Supreme Court. Rodolfo T. Arambulo filed a Motion for Execution of this judgment, asserting his ownership of 1/7 of the Piedras shares and seeking the release of dividends and cessation of interference. The Republic opposed this motion, arguing Arambulo was not a party to the Compromise Agreement. The Sandiganbayan issued a Resolution on July 11, 1997, declaring Arambulo the owner of his Piedras shares and ordering the release of dividends and cessation of interference. A subsequent Resolution on February 3, 1998, denied the Republic's motion for reconsideration. A Writ of Execution was issued on March 23, 1998. The Republic's initial petition for certiorari (G.R. No. 133096) was dismissed by the Supreme Court for being filed one day late. The Petition: The Republic of the Philippines, represented by the PCGG, filed the instant petition for annulment of the Sandiganbayan's Resolutions dated July 11, 1997, and February 3, 1998, under Rule 47 of the Rules of Civil Procedure. The grounds cited are lack of jurisdiction or grave abuse of discretion, and deprivation of due process. The petitioner argues that the Sandiganbayan declared Arambulo the owner of the shares and awarded him P144.12 Million without requiring him to present evidence, and that he was not a party to the Compromise Agreement. The petition also contends that the dismissal of the prior certiorari petition (G.R. No. 133096) should not bar this action for annulment, as it was filed out of time due to circumstances beyond their control. The petitioner seeks to annul the Sandiganbayan's resolutions and enjoin the execution of the writ.
Issue(s)
Whether the petitioner was deprived of due process of law when the Sandiganbayan resolved the motion for execution in favor of respondent Arambulo without requiring the parties to present their respective evidence. Whether the dismissal of the petition for certiorari in G.R. No. 133096 bars the filing of the instant petition for annulment of judgment.
Ruling
The Supreme Court dismissed the petition for annulment of judgment for lack of merit and recalled the temporary restraining order. The Court found that the petitioner was not deprived of due process and that the dismissal of the prior petition for certiorari was a bar to the present action.
Ratio Decidendi
On the issue of due process: The Court found the petitioner's contention untenable. The Sandiganbayan provided both parties ample opportunity to present their evidence, as evidenced by the petitioner's submission of oppositions to Arambulo's motion for execution and subsequent arguments. The essence of due process is the opportunity to be heard, which was afforded to the petitioner. Furthermore, the Sandiganbayan's Resolution of July 11, 1997, provided detailed ratiocinations explaining its conclusion that Arambulo was the subscriber-owner of the Piedras shares. These reasons included the fact that the original sequestration order over Arambulo's shares was automatically lifted due to the failure of the PCGG to file the corresponding judicial action within the prescribed period under Section 26, Article XVIII of the 1987 Constitution. The Court also noted that the Deed of Confirmation executed by Benedicto identified Arambulo as a nominee but did not necessarily imply Benedicto's ownership of the shares registered in Arambulo's name, as the deed allowed for ownership by Benedicto, Arambulo, and/or other nominees. Crucially, none of the other nominees, including Benedicto himself, asserted exclusive ownership over Arambulo's shares, and Arambulo was the only one claiming exclusive ownership. The Court also pointed out that the Compromise Agreement and its annexes did not list Arambulo's Piedras shares as assets ceded to the Government, and that the sequestration order, if still in effect, should be lifted under the general stipulation for sequestered assets not ceded to the Republic. On the issue of res judicata and forum shopping: The Court held that the dismissal of the prior petition for certiorari in G.R. No. No. 133096, due to being filed one day late, barred the present petition for annulment of judgment. The Court emphasized that a condition for availing of an annulment of judgment under Rule 47 is that the petitioner failed to avail of other appropriate remedies without fault attributable to them. Since the petitioner failed to file its petition for certiorari within the reglementary period without sufficient justification, it could not resort to an action for annulment. The Court distinguished this from cases where it treated late petitions as actions for annulment, stating that in the present case, the petition was not prima facie meritorious, as the assailed Sandiganbayan Resolutions were found to have adequately explained their basis.
Main Doctrine
A petition for annulment of judgment under Rule 47 of the Rules of Civil Procedure is not a substitute for lost remedies due to negligence or inaction. If a party fails to avail of ordinary remedies like appeal or petition for certiorari within the reglementary period without sufficient justification, they cannot resort to an action for annulment.