G.R. No. 111857 December 6, 1996
Jaime Calpo, Tirso Antiporda, Jr., Juliet C. Bertuben, Ide Tillah, Juan J. Carlos, Emmanuel Cruz, Ricardo R. de la Cruz and Presidential Commission on Good Government (PCGG) vs. Sandiganbayan (Third Division), Enrique M. Cojuangco, Manuel M. Cojuangco, Marcos O. Cojuangco, Estelito P. Mendoza, Gabriel L. Villareal and Douglas Lu Ym.

FACTS

The PCGG sequestered shares in San Miguel Corporation (SMC) from various corporations in 1986, alleging they were ill-gotten. These corporations secured a Sandiganbayan ruling in 1992 declaring the sequestration automatically lifted. The PCGG challenged this in the Supreme Court in G.R. No. 104850, which was consolidated with other related cases. Pending this Supreme Court review, the Court issued orders restraining the corporations from voting the sequestered shares in SMC stockholders’ meetings. Consequently, the PCGG voted these shares in the 1993-1994 election, resulting in the defeat of the Cojuangco group’s nominees.
The Cojuangco group then filed a quo warranto petition (S.B. Case No. 0150) before the Sandiganbayan against the winning PCGG nominees. They argued the PCGG nominees were disqualified for not owning the required 5,000 SMC shares and that the PCGG lacked authority to vote the shares. The PCGG moved to suspend the quo warranto proceedings, contending the issue of the right to vote the shares was sub judice in the pending Supreme Court cases. The Sandiganbayan denied the motion, ruling the issues in the quo warranto case were independent from those in the Supreme Court.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in denying the motion to suspend the quo warranto proceedings pending the Supreme Court’s resolution of G.R. No. 104850 and related cases.

RULING

No. The Supreme Court held the Sandiganbayan did not commit grave abuse of discretion. The core issue in the consolidated Supreme Court cases (G.R. No. 104850, et al.) was the validity of maintaining the sequestration of the SMC shares based on constitutional and procedural grounds. In contrast, the quo warranto case before the Sandiganbayan presented a distinct and separate issue: the qualification of the PCGG-nominated directors based on SMC’s by-law requirement of share ownership and the PCGG’s authority to vote the shares in the election. The resolution of the sequestration’s validity in the Supreme Court would not automatically resolve the specific corporate law issue of director qualifications in the quo warranto case. Therefore, the proceedings could proceed independently without rendering the Supreme Court cases moot. The Sandiganbayan’s decision to proceed was a proper exercise of its discretion, as the cases involved different causes of action and legal questions.