People v. Reyes
NEW DOCTRINEFacts
The Antecedents: The Anti-Money Laundering Council (AMLC) issued freeze orders against various bank accounts of respondents, finding them prima facie related to unlawful activities. The AMLC sought to extend the effectivity of these freeze orders by filing petitions with the Court of Appeals (CA), believing the CA had the power to grant such extensions under Section 10 of Republic Act No. 9160. Procedural History: The CA dismissed the AMLC's petitions, ruling that it was not vested with the power to extend freeze orders. The AMLC then filed consolidated petitions before the Supreme Court. The Petition: The consolidated petitions presented a common issue: which court has jurisdiction to extend the effectivity of a freeze order. During the pendency of these petitions, Congress enacted Republic Act No. 9194, amending Section 10 of Republic Act No. 9160 to explicitly grant the Court of Appeals the power to extend freeze orders. The Office of the Solicitor General moved to remand the cases to the CA and sought a TRO, which the Supreme Court granted.
Issue(s)
Whether the Court of Appeals has jurisdiction to extend the effectivity of freeze orders issued by the Anti-Money Laundering Council. Whether the petitions filed before the Supreme Court have become moot.
Ruling
The Supreme Court dismissed G.R. No. 154694 for being moot, and remanded G.R. Nos. 154522, 155554, and 155711 to the Court of Appeals for appropriate action. The temporary restraining order issued on April 21, 2003, was maintained pending resolution by the Court of Appeals.
Ratio Decidendi
On the jurisdiction to extend freeze orders: The Court held that the amendment introduced by Republic Act No. 9194 to Section 10 of Republic Act No. 9160 clarified the jurisdiction over the extension of freeze orders. As amended, the law explicitly states that the Court of Appeals, upon application ex parte by the AMLC and after determining probable cause, may issue a freeze order which shall be effective for twenty (20) days unless extended by the court. This amendment erased any doubt regarding the CA's authority in this regard. The Court emphasized that the CA now has the sole and exclusive jurisdiction to extend existing freeze orders previously issued by the AMLC concerning accounts and deposits related to money-laundering activities. The original interpretation by the AMLC that the phrase "upon order of the court" in the original RA 9160 referred to the CA was ultimately validated by the legislative amendment. On the mootness of G.R. No. 154694: The Court dismissed G.R. No. 154694 as moot. This was because, subsequent to the filing of the petition before the Supreme Court, Republic Act No. 9194 was enacted, which amended the relevant provisions of Republic Act No. 9160. Furthermore, the Court noted that on April 22, 2003, the Court of Appeals itself issued a resolution in CA-G.R. SP No. 69371 (the subject of G.R. No. 154694) granting the petition for extension of freeze orders. This action by the CA rendered the issue before the Supreme Court concerning the initial dismissal of the petition moot and academic, as the CA had subsequently exercised the very power that was in question.
Main Doctrine
The Court of Appeals has the sole authority to extend the effectivity of freeze orders issued by the Anti-Money Laundering Council (AMLC) under Republic Act No. 9160, as amended by Republic Act No. 9194.