G.R. Nos. 215527-28. March 22, 2023.
Presidential Commission on Good Government, Julieta C. Bertuben, Ide C. Tillah, Emmanuel E. Cruz, Sergio Osmeña III, Tirso Antiporda Jr., Victor S. Ziga, Luis M. Mirasol, Jr., and Jose Y. Feria, Petitioners, vs. Eduardo M. Cojuangco Jr., Enriquez M. Cojuangco, Manuel M. Cojuangco, Estelito P. Mendoza, and Gabriel L. Villareal, Respondents.

FACTS

During the 1995 and 1996 annual stockholders’ meetings of San Miguel Corporation (SMC), the individual petitioners (PCGG nominees) and the respondents vied for seats on the SMC Board of Directors. The PCGG voted sequestered shares belonging to 436 corporate stockholders (Corporate Shares) in favor of its nominees, leading to their election. Respondent Estelito P. Mendoza, as appointed proxy for these corporate shareholders, voted the same shares in favor of the respondents. Mendoza protested the election results, arguing the PCGG lacked authority to vote the shares and that the registration of shares in the nominees’ names was improper. After the Sandiganbayan initially dismissed the resulting quo warranto petitions for lack of jurisdiction, the Supreme Court in Cojuangco, Jr. v. Sandiganbayan directed the Sandiganbayan to take cognizance of the cases. Petitioners then filed motions to dismiss (on grounds of mootness due to expired terms) or to hold in abeyance, instead of responsive pleadings. The Sandiganbayan partially granted the quo warranto petitions, declaring the 1995 and 1996 elections of the individual petitioners void, ruling the PCGG had no authority to vote the Corporate Shares. Petitioners sought reconsideration, reiterating mootness arguments and citing the Supreme Court’s decision in Republic v. Sandiganbayan. The Sandiganbayan denied reconsideration.

ISSUE

Whether the Sandiganbayan correctly proceeded to rule on the merits of the quo warranto petitions despite the expiration of the terms of office of the individual petitioners as members of the SMC Board for 1995 and 1996.

RULING

No. The Supreme Court granted the Petition, ruling that the Sandiganbayan should have dismissed the quo warranto petitions for being moot and academic. The expiration of the individual petitioners’ terms of office was a supervening event that rendered the petitions moot, as a judgment of ouster would serve no practical purpose. The Court distinguished this case from prior rulings like Cojuangco Jr. (1991), Antiporda, and PCGG v. Cojuangco Jr. (1999), where quo warranto cases involving PCGG nominees were resolved despite expired terms because the main sequestration suits were still pending, making the issue of voting rights a recurring, justiciable controversy. Here, the Supreme Court had already rendered a final and executory decision in Republic v. Sandiganbayan, which definitively resolved the ownership of the sequestered SMC shares subject of the case, including the Corporate Shares. With the ownership issue settled in the main case, the ancillary question of the PCGG’s authority to vote those shares during the 1995 and 1996 elections was rendered moot. The exceptions to the mootness doctrine did not apply because the issue was not capable of repetition yet evading review, as the root cause of the controversy—the unresolved ownership of the sequestered shares—had been conclusively determined.