Universal Broadcasting v. Sandiganbayan
REITERATIONFacts
The Antecedents: The Presidential Commission on Good Government (PCGG) issued a writ of sequestration over the Price Mansion property, allegedly owned by former Leyte Governor Benjamin Romualdez. Tacloban City Ice Plant, Inc. (TCIP) claimed ownership and sought the lifting of the sequestration, which was granted by the Sandiganbayan. TCIP later sold the property to Allied Banking Corporation as trustee of College Assurance Plan Philippines, Inc. (CAP). TCIP filed a motion for compliance to compel PCGG to turn over the entire property, including a portion where an antenna/tower of PRTV-12 was erected. The Sandiganbayan granted this motion and declared its earlier resolution final. Procedural History: PCGG moved for reconsideration, presenting documents showing TCIP had sold the property to Universal Broadcasting Corporation (UBC) prior to sequestration. The Sandiganbayan denied this motion. PCGG filed a petition for certiorari with the Supreme Court (G.R. No. 106413), alternatively praying for a writ of mandamus to compel the Sandiganbayan to determine the ill-gotten nature of the property. UBC filed a motion for leave to intervene and a complaint-in-intervention claiming ownership, which the Sandiganbayan denied, suggesting a separate action in a regular court. Consequently, UBC filed a complaint for annulment of titles with the RTC of Tacloban City (Civil Case No. 94-01-18). The Petition: The Supreme Court, in G.R. No. 106413, granted the Republic's alternative prayer, ordering the Sandiganbayan to conduct a hearing to determine UBC's claim of ownership and the Republic's right to retain possession. The Sandiganbayan subsequently issued a resolution directing TCIP and UBC to appear and present evidence. UBC filed a comment praying for the suspension of proceedings pending the RTC's determination. The Sandiganbayan, in its assailed resolutions, ordered UBC to file anew its motion for intervention with its complaint-in-intervention and set it for hearing. UBC's motion for reconsideration was denied, leading to the present petition for certiorari and prohibition, questioning the Sandiganbayan's jurisdiction and its order for UBC to present evidence ahead of other parties.
Issue(s)
Whether the Sandiganbayan acted with grave abuse of discretion amounting to lack or excess of jurisdiction in ordering petitioner UBC to submit a motion for intervention attaching thereto its complaint-in-intervention, considering its arguments regarding jurisdiction and impleading. Whether the Sandiganbayan acted with grave abuse of discretion in requiring UBC to present its evidence ahead of the other parties, in light of the Supreme Court's directives.
Ruling
The petition is DISMISSED. The Sandiganbayan did not act with grave abuse of discretion.
Ratio Decidendi
On the Sandiganbayan's jurisdiction over UBC: The Court held that the Sandiganbayan acquired jurisdiction over UBC. Petitioner's submission that it was not impleaded as a party-defendant in Civil Case No. 0035 and thus the Sandiganbayan never acquired jurisdiction over it was found to be without merit. The Price Mansion property is an asset alleged to be ill-gotten, and UBC is listed as among the properties of Benjamin Romualdez and among the corporations listed as alleged repositories of shares of stock controlled by Romualdez. The Court reiterated its ruling in Republic v. Sandiganbayan that there is no need to implead firms which are merely the res of the actions in ill-gotten wealth cases, and that judgment may simply be directed against the assets. Such corporations are simply the res in the actions for the recovery of illegally acquired wealth, and there is, in principle, no cause of action against them and no ground to implead them as defendants in said actions. Furthermore, UBC is estopped from questioning the jurisdiction of the respondent court after it had voluntarily filed pleadings and appeared in several hearings in Civil Case No. 0035. In fact, UBC admits that it filed its comment to a resolution and prayed for the suspension of proceedings. On the Sandiganbayan's order for UBC to present evidence: The Court found that the Sandiganbayan's resolutions were in compliance with the Supreme Court's directive in its July 5, 1996 decision and August 14, 1996 resolution in G.R. No. 106413. In those issuances, the Supreme Court ordered the Sandiganbayan to conduct a hearing and determine the claim of ownership of UBC over the property in question. The Court's resolution of August 14, 1996, in G.R. No. 106413, also pronounced that the proceedings before the Sandiganbayan may proceed independently of Civil Case No. 94-01-18 then pending at the RTC of Tacloban City. Therefore, the Sandiganbayan's order for UBC to submit its motion for intervention and present its evidence was a procedural step to comply with the Supreme Court's directive to determine the ownership claim.
Main Doctrine
A corporation whose assets are alleged to be ill-gotten wealth, and which is merely the 'res' of an action for recovery, need not be impleaded as a party-defendant. Furthermore, a party who voluntarily files pleadings and appears in hearings before a court is estopped from questioning that court's jurisdiction.