Republic v. Sandiganbayan
REITERATIONFacts
The Antecedents: Manuel G. Montecillo, Eduardo M. Cojuangco, Jr., Cesar C. Zalamea, and Jose Y. Campos organized Hans M. Menzi Holdings and Management Inc. (HMHMI) in 1982 as a holding company for shares in Bulletin Publishing Corporation and other companies. Hans M. Menzi died in 1984, and Montecillo was appointed executor of his estate and president of HMHMI. The Presidential Commission on Good Government (PCGG) issued Sequestration Writ No. 87-0206 on February 12, 1987, against HMHMI's assets, shares, properties, records, and bank deposits, and instructed financial institutions to disallow withdrawals. Procedural History: On July 29, 1987, the Republic filed a complaint for reconveyance, reversion, accounting, restitution, and damages (Civil Case No. 0022) against Montecillo, Cojuangco, Jr., Zalamea, Ferdinand E. Marcos, and Imelda R. Marcos. The estate of Hans M. Menzi was later named a defendant via a Second Amended Complaint on October 17, 1990. On November 27, 1992, the estate of Hans M. Menzi, on behalf of HMHMI, moved to lift the freeze order, arguing that HMHMI was sequestered without a judicial action or being impleaded as a defendant, and that the sequestration order automatically lapsed due to the failure to file a corresponding judicial action within the constitutional reglementary period. The Sandiganbayan granted this motion on April 2, 1992, and denied reconsideration on October 2, 1992. The Republic appealed this to the Supreme Court (G.R. No. 107377), which set aside the Sandiganbayan's resolution and remanded the case for determination of the prima facie factual basis for the sequestration. On April 13, 1998, the Sandiganbayan lifted the writ, finding no prima facie factual basis. The motion for reconsideration was denied on August 21, 1998. The Petition: The Republic filed a petition for certiorari under Rule 65 of the Revised Rules of Court, seeking to nullify the Sandiganbayan's resolutions dated April 13, 1998, and August 21, 1998.
Issue(s)
Whether there was a prima facie factual basis for the issuance of the writ of sequestration over the assets, shares of stock, property, records, and bank deposits of HMHMI. Whether the Sandiganbayan committed grave abuse of discretion in lifting the writ of sequestration.
Ruling
The Court denies the petition. It holds that the issue of whether there was a prima facie factual basis for the writ of sequestration is a question of fact, which the Supreme Court, as a trier of facts, cannot resolve. The Court finds no grave abuse of discretion on the part of the Sandiganbayan in adopting its resolutions lifting the writ of sequestration.
Ratio Decidendi
On the issue of whether there was a prima facie factual basis for the issuance of the writ of sequestration: The Court reiterated the well-settled principle that its appellate jurisdiction over decisions of the Sandiganbayan is limited to questions of law, not questions of fact. A question of fact arises when the doubt or controversy concerns the truth or falsehood of facts or requires an examination and calibration of the probative value of the evidence presented. Conversely, a question of law exists when the doubt or controversy concerns the correct application of law or jurisprudence to a certain set of facts, or when the issue does not call for an examination of the evidence. The Supreme Court is not a trier of facts and does not re-examine evidence presented below. The Sandiganbayan, having full authority to decide on all incidents in ill-gotten wealth cases, including the propriety of sequestration writs, found no prima facie factual basis for the issuance of the writ in question based on the evidence presented. The Court found no competent evidence thus far showing that President Ferdinand E. Marcos or his cronies acquired Bulletin shares of the late Hans M. Menzi or HMHMI that would be subject to sequestration. On whether the Sandiganbayan committed grave abuse of discretion: The Court found no grave abuse of discretion on the part of the Sandiganbayan. The petition for certiorari under Rule 65 is a remedy for extraordinary abuses of discretion amounting to lack of jurisdiction. Since the core issue presented by the petitioner was factual in nature—whether a prima facie factual basis existed for the sequestration—and the Sandiganbayan, as the tribunal with the authority to determine such factual matters, had already made its determination, the Supreme Court would not interfere. The Court's role is to correct errors of law, not to re-evaluate factual findings unless there is a showing of grave abuse of discretion that would warrant such intervention. In this case, the petitioner failed to demonstrate such grave abuse.
Main Doctrine
The Supreme Court is not a trier of facts and limits its appellate jurisdiction over Sandiganbayan decisions to questions of law. A factual issue arises when the doubt concerns the truth or falsehood of facts or requires calibration of evidence, while a legal issue involves the correct application of law or jurisprudence.