Presidential Commission on Good Government v. Cojuangco
REITERATIONFacts
The Antecedents: During the 1995 and 1996 annual stockholders' meetings of San Miguel Corporation (SMC), the Presidential Commission on Good Government (PCGG) nominated individual petitioners, registering sequestered corporate shares in their names to qualify them for the SMC Board of Directors. The PCGG voted these shares in favor of its nominees. Conversely, respondent Estelito P. Mendoza, as proxy for the corporate shareholders, voted the same shares in favor of the respondents. Following the elections, the PCGG nominees were declared elected, while the respondents were not. This led to protests questioning the PCGG's authority to vote the sequestered shares and the propriety of registering them in the names of the individual petitioners, who allegedly did not meet the share ownership requirement. Procedural History: Respondents initiated quo warranto petitions before the Sandiganbayan in Civil Case SB Nos. 0166 and 0169, challenging the election of the PCGG nominees in 1995 and 1996, respectively. The Sandiganbayan initially dismissed these petitions for lack of jurisdiction, but this Court, in Cojuangco, Jr. v. Sandiganbayan, ruled that the Sandiganbayan has jurisdiction over such petitions when they arise from or relate to PCGG cases concerning alleged ill-gotten wealth. Consequently, the Sandiganbayan was directed to give due course to the petitions. Despite orders to file responsive pleadings, the petitioners filed motions to dismiss based on mootness and to hold proceedings in abeyance. The Sandiganbayan, in its Decision dated July 15, 2014, partially granted the petitions, declaring the elections of the individual petitioners void. A subsequent motion for reconsideration was denied by the Sandiganbayan in its Resolution dated November 25, 2014. The Petition: The petitioners filed a Petition for Review on Certiorari with this Court, assailing the Sandiganbayan's decision and resolution. They argue that the quo warranto petitions should have been dismissed for mootness due to subsequent SMC Board elections and this Court's decision in Republic v. Sandiganbayan, which declared the Cojuangco et al. block of SMC shares as the exclusive property of the registered owners. Alternatively, petitioners contend that they were denied due process as the Sandiganbayan ruled on the merits without allowing them to present evidence. The petitioners seek the reversal and setting aside of the Sandiganbayan's rulings and the dismissal of the quo warranto petitions.
Issue(s)
Whether the quo warranto petitions were rendered moot and academic by supervening events, specifically the expiration of the term of office of the elected directors and the Supreme Court's decision in Republic v. Sandiganbayan. Whether the exceptions to the mootness doctrine apply in this case. Whether petitioners were denied due process.
Ruling
The Supreme Court granted the petition, reversing and setting aside the Sandiganbayan's decision and resolution. The quo warranto petitions were dismissed for being moot and academic.
Ratio Decidendi
On the issue of mootness: The Court held that the quo warranto petitions were rendered moot and academic by the expiration of the term of office of the individual petitioners as members of the SMC Board for the years 1995 and 1996. A quo warranto judgment ousting respondents would serve no practical purpose as there would be no one to oust. The Court clarified that while expiration of term does not automatically dismiss a quo warranto case, it does so when it renders the issue non-justiciable. The Court distinguished this case from Cojuangco Jr. [1991], Antiporda, and PCGG [1999] where the main sequestration suit was still pending, making the issue of voting rights on sequestered shares a justiciable controversy affecting future elections. In the present case, the Supreme Court's decision in Republic v. Sandiganbayan definitively resolved the ownership of the Corporate Shares, thereby settling the incidental issue of the PCGG's authority to vote them. This resolution of ownership rendered the quo warranto petitions moot and academic, as the right to vote shares is an incident of ownership. The Court emphasized that the Republic decision laid to rest any and all issues regarding the PCGG's authority to vote the sequestered shares. On the exceptions to mootness: The Court disagreed with the Sandiganbayan that the exceptions to the mootness principle applied. It found that the Assailed Decision did not formulate new principles for the guidance of the bench, bar, and public, as the scope of PCGG's authority over sequestered shares had long been settled in cases like BASECO and Cojuangco Jr. [1991]. The Court also found that the case was not capable of repetition yet evading review because the Republic decision had already resolved the core issue of ownership, removing the expectation of future litigation on the same matter concerning these specific shares. The second element for this exception – a reasonable expectation that the same complaining party would be subjected to the same action again – was absent due to the definitive ruling on ownership. On the issue of due process: The Court found it unnecessary to discuss the alleged denial of due process, given its ruling that the petitions were moot and academic.
Main Doctrine
A quo warranto petition becomes moot and academic when the term of office of the individuals whose election is being questioned has expired, especially when a subsequent definitive ruling on the ownership of the shares in question has been made, rendering the issue of voting authority moot.