G.R. No. 110296 October 30, 1996
MID-PASIG LAND DEVELOPMENT CORPORATION, represented by the PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT, petitioner, vs. SANDIGANBAYAN, and RICARDO C. SILVERIO for and in behalf of ANCHOR ESTATE CORPORATION, respondents.

FACTS

Ricardo C. Silverio, on behalf of Anchor Estate Corporation, filed a complaint with the Sandiganbayan against the Presidential Commission on Good Government (PCGG), the Asset Privatization Trust, Mid-Pasig Land Development Corporation, and Ortigas and Company. The complaint alleged that Anchor had purchased a 16-hectare parcel of land in Pasig in 1968, but title was later transferred to Mid-Pasig. An additional 2.4 hectares was also sold to Mid-Pasig. After the 1986 revolution, Jose Y. Campos, the president and majority stockholder of both Anchor and Mid-Pasig, turned over control of the corporations and the titles to the PCGG, claiming he and other shareholders were nominees of former President Ferdinand Marcos. Silverio, claiming ownership of a 30% balance in Anchor, sought reconveyance of the now highly valuable 18.2-hectare property.
When Mid-Pasig, represented by the PCGG, failed to file an answer to the amended complaint, Silverio moved to declare it in default. The Sandiganbayan granted the motion. The PCGG filed a petition for certiorari before the Supreme Court, arguing it was not duty-bound to answer the amended complaint pending resolution of the motion to declare default and that any failure was due to a mistake on a difficult legal question. The Supreme Court gave due course and, during oral arguments, raised additional issues concerning the Sandiganbayan’s jurisdiction and Silverio’s standing as a real party in interest.

ISSUE

Whether the Sandiganbayan’s order declaring Mid-Pasig in default should be set aside.

RULING

The Supreme Court granted the petition and set aside the Sandiganbayan’s default order. The legal resolution was based not on a merits-based analysis of the procedural or jurisdictional arguments initially presented, but on a subsequent procedural development that rendered those issues moot. During the pendency of the case, private respondent Ricardo C. Silverio filed a “Manifestation and Confession of Judgment.” In this pleading, he withdrew his objections to the petition and his efforts to have Mid-Pasig declared in default, expressly stating that the prayer for relief in the petition could be granted to avoid further delay. The Court held that with this voluntary submission by the opposing party, there was no longer any necessity to pass upon the original grounds of the petition concerning the propriety of the default declaration or the ancillary jurisdictional questions. Consequently, the Court granted Silverio’s motion, set aside the default resolutions, and gave the PCGG a period within which to file its answer to the amended complaint.