Republic v. Sandiganbayan
REITERATIONFacts
The Antecedents: From 1986 to 1988, the Presidential Commission on Good Government (PCGG) issued sequestration orders against assets and documents of corporations allegedly owned by associates of the Marcoses. On July 23, 1987, the Republic of the Philippines (Government), through the PCGG, filed a complaint (Civil Case 0014) against former President Marcos, Imelda Marcos, and the Enriquez group for recovery of ill-gotten wealth, listing respondent corporations as assets and shell corporations. In October 1991, the Government moved to amend the complaint to implead respondent corporations, alleging they were beneficially owned or controlled by the individual defendants and used as fronts for fraudulent schemes or to evade liabilities. Procedural History: Several respondent corporations challenged the sequestration orders, arguing no judicial action was filed within the constitutional period. The Sandiganbayan initially issued a writ of preliminary injunction, which this Court set aside in Republic of the Philippines v. Sandiganbayan, holding that impleading corporations was not necessary and the complaint could be considered a judicial action. Subsequently, the Sandiganbayan admitted the amended complaint. Respondent corporations then filed motions to dismiss and lift sequestration, citing the Republic case and claiming no cause of action. The Sandiganbayan granted these motions, holding that impleading the corporations was unnecessary and the amended complaint stated no cause of action, and lifted the sequestration orders. The Government's motion for reconsideration was denied. The Government filed a petition for certiorari. The Petition: The Government filed a petition for certiorari under Rule 65 of the Rules of Court, assailing the Sandiganbayan's resolutions dismissing the complaint against the respondent corporations and lifting the sequestration orders.
Issue(s)
Whether or not the petition for certiorari under Rule 65 is the proper remedy to assail the resolutions of the Sandiganbayan. Whether or not the Sandiganbayan gravely abused its discretion in dismissing the complaint against respondent corporations on the grounds that there was no need for it and that the amendment did not state a cause of action against such corporations. Whether or not the Sandiganbayan gravely abused its discretion in lifting the sequestration orders against the subject corporations.
Ruling
The Court dismissed the petition for lack of merit and affirmed the Sandiganbayan's resolutions dated February 7, 2002, and June 14, 2002.
Ratio Decidendi
On the propriety of the remedy: The Court ruled that a petition for certiorari under Rule 65 was not the proper remedy. An order of dismissal is a final order, which is the proper subject of an appeal through a petition for review. The remedies of appeal and special civil action of certiorari are mutually exclusive, and certiorari will not be entertained where an appeal is available, even if the ground is grave abuse of discretion, unless exceptions are shown. In this case, no exceptions were demonstrated by the Government. On the dismissal of the complaint: The Court found that the Sandiganbayan committed no grave abuse of discretion in dismissing the complaint against the respondent corporations. The Sandiganbayan correctly relied on this Court's ruling in the Republic case, which held that impleading corporations capitalized with ill-gotten wealth is unnecessary as judgment can be rendered against the individual defendants' shares. Furthermore, the Court reiterated in Universal Broadcasting Corporation v. Sandiganbayan that if corporations are merely the res of ill-gotten wealth and not guilty of wrongdoing, they need not be impleaded. The dismissal was also justified because the amended complaint stated no cause of action against the corporations, as it failed to allege any specific acts by the corporations themselves that violated a right vested in the Government. The complaint focused on the alleged acts of the individual defendants, not the corporate entities. On the lifting of sequestration orders: The Court held that while impleading the corporations was not necessary to maintain sequestration, the orders themselves were properly lifted for other reasons. Firstly, the April 11, 1986 PCGG Rules and Regulations required at least two commissioners' signatures on a sequestration order, and orders signed by only one commissioner were deemed null and void. Secondly, sequestration orders must be issued upon a showing of a prima facie case that the properties are ill-gotten wealth, as mandated by the Constitution. The Court found that the sequestration orders against Philippine Village, Philroad, and Silahis, signed by only one commissioner, were void. The order against Ternate, and the supplemental order including Fantasia, Monte Sol, Olas del Mar, and Puerto Azul, lacked a clear showing of a prima facie case that the sequestered properties were ill-gotten wealth. The Government's reliance on a presumption that the PCGG acted lawfully was insufficient to overcome the constitutional requirement of accountability and the need for a factual foundation for such a harsh remedy.
Main Doctrine
A petition for certiorari under Rule 65 is not the proper remedy to assail a dismissal order, which is a final order subject to appeal. Furthermore, impleading corporations as defendants is unnecessary when the complaint alleges they were capitalized with ill-gotten wealth, as judgment can be rendered against the individual defendants' shares. Sequestration orders must be supported by a prima facie showing that the properties are ill-gotten wealth and must comply with procedural requirements, such as the required number of signatures.