G.R. No. 108292 , G.R. No. 108368, G.R. Nos. 108548-49, G.R. No. 108550. September 10, 1993.
Case Parties:

REPUBLIC OF THE PHILIPPINES (Presidential Commission on Good Government [PCGG]), petitioner, vs. SANDIGANBAYAN, JOSE L. AFRICA, MANUEL H. NIETO, JR., FERDINAND E. MARCOS, IMELDA R. MARCOS, FERDINAND R. MARCOS, JR., ROBERTO S. BENEDICTO, JUAN PONCE ENRILE, and POTENCIANO ILUSORIO, respondents.
REPUBLIC OF THE PHILIPPINES, petitioner, vs. SANDIGANBAYAN, ROBERTO S. BENEDICTO, ET AL., respondents.
JOSE MA. B. MONTINOLA, ROMEO G. GUANZON, HORTENSIA STARKE, VICENTE LOPEZ, JR., MANUEL ESCALANTE, ROMAN M. MIRASOL, JESUS T. TALEON, JESUS S. MONTERO, RODOLFO T. TIONGSON, JR., PABLO G. LIM, JULIO LEDESMA, CENTRAL AZUCARERA DON PEDRO, SAN CARLOS MILLING, CO., INC., petitioners, vs. SANDIGANBAYAN and ROBERTO S. BENEDICTO, respondents.
JOSE MA. B. MONTINOLA, ROMEO G. GUANZON, HORTENSIA STARKE, VICENTE LOPEZ, JR., MANUEL ESCALANTE, ROMAN M. MIRASOL, JESUS T. TALEON, JESUS S. MONTERO, RODOLFO T. TIONGSON, JR., PABLO G. LIM, JULIO LEDESMA, CENTRAL AZUCARERA DON PEDRO, SAN CARLOS, MILLING, CO., INC., petitioners, vs. THE SANDIGANBAYAN and ROBERTO S. BENEDICTO, respondents.

FACTS

The consolidated petitions seek the nullification of a compromise agreement dated November 3, 1990, executed between Roberto S. Benedicto and the PCGG, and the Sandiganbayan decision dated October 2, 1992, approving it. The agreement settled several civil cases (Civil Case Nos. 0009, 00234, 0034, the Phil-Asia case, and PCGG I.S. No. 1) for reconveyance, reversion, accounting, restitution, and damages against former President Ferdinand E. Marcos, his family, and alleged cronies including Benedicto. It was the third in a series of global settlements, following earlier agreements in the United States and Switzerland.
Under the agreement, Benedicto and his group ceded specified properties (listed in Annex A) and assigned rights over corporate assets (listed in Annex B) to the government. In return, the PCGG lifted sequestrations over properties listed in Annex C and other assets, and granted Benedicto, his family, and corporate officers absolute immunity from criminal investigation or prosecution for acts prior to February 25, 1986, related to the acquisition of the assets. The government also agreed not to object to the issuance or restoration of the Benedictos’ passports.
The PCGG, in its petitions, contended the Sandiganbayan committed grave abuse of discretion in approving an agreement with provisions contrary to law, morals, good customs, public policy, and public order, and that its consent was vitiated by fraud and misrepresentation. Separate petitions were filed by sugar cane planters and milling corporations seeking to intervene in the underlying civil cases, arguing the compromise prejudiced their claims for compensation for the alleged plunder of the sugar industry.

ISSUE

1. Whether the Sandiganbayan committed grave abuse of discretion in approving the compromise agreement between the PCGG and Roberto S. Benedicto.
2. Whether the PCGG is estopped from questioning the validity of the compromise agreement.
3. Whether the sugar planters and millers should be allowed to intervene in the civil cases after the Sandiganbayan’s decision approving the compromise.

RULING

The Supreme Court DISMISSED all petitions and UPHELD the Sandiganbayan’s approval of the compromise agreement.
1. On the Validity and Approval of the Compromise Agreement: The Court found no grave abuse of discretion by the Sandiganbayan. It reiterated its settled doctrine that the PCGG has the authority to enter into compromise agreements in civil cases and to grant immunity in criminal cases to recover ill-gotten wealth. The Sandiganbayan correctly found the agreement was entered into freely, voluntarily, and with full understanding by the parties, and its terms did not appear contrary to law, morals, or public policy on its face.
2. On Estoppel of the PCGG: The Court held the PCGG was in estoppel to repudiate the agreement. A compromise, upon perfection, is binding and has the effect of res judicata. The PCGG had already received and enjoyed substantial benefits from the agreement, including: (a) control of Oriental Petroleum shares valued at over P1 billion; (b) control and management of Broadcast City (Channel 13) assets estimated at P450 million; (c) turnover of California Overseas Bank (capital: US$18M); and (d) receipt of US$16.271 million. The total value transferred exceeded P2.336 billion. A party cannot unilaterally rescind a compromise after enjoying its benefits, and mere dissatisfaction with the terms is not a valid ground for rescission absent vitiated consent.
3. On the Intervention of the Sugar Planters and Millers: The Court denied the motion for intervention. The movants filed their motion after the Sandiganbayan had already promulgated its decision approving the compromise. Intervention must be made before or during a trial, not after judgment. Furthermore, under the Rules of Court, intervention may be disallowed if the intervenor’s rights can be fully protected in a separate proceeding. The Court ruled that the petitioners’ claims for compensation could be pursued in a separate action before the Sandiganbayan, which has jurisdiction over incidents related to ill-gotten wealth cases.
The Court lifted the temporary restraining orders and ordered the parties to strictly comply with the terms of the compromise agreement.