GR 114135; (October, 1994) (Digest)
G.R. No. 114135 October 7, 1994
LEON M. GARCIA, JR., petitioner, vs. THE SANDIGANBAYAN, PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT, et al., respondents.
FACTS
Petitioner Leon M. Garcia, Jr. was elected to the Board of Directors of United Coconut Planters Bank (UCPB) in 1990 as a nominee of the Presidential Commission on Good Government (PCGG). In 1993, the PCGG Chairman, acting upon instruction from the Office of the President, informed Garcia that his membership on the Board was terminated. Garcia refused to resign, asserting that his removal must comply with the Corporation Code and citing jurisprudence that the PCGG cannot unilaterally change the board composition of sequestered corporations. The UCPB Board subsequently held a special meeting, deemed Garcia terminated, and replaced him with respondent Cesar Sevilla.
Garcia filed a petition with the Sandiganbayan seeking prohibition, mandamus, and quo warranto, with damages and a prayer for injunction. He sought to prohibit Sevilla from acting as a director, compel his own reinstatement, and oust Sevilla from the office. The Sandiganbayan, however, focused on the threshold issue of its own jurisdiction over the special civil actions filed.
ISSUE
Whether the Sandiganbayan has jurisdiction over special civil actions for prohibition, mandamus, and quo warranto.
RULING
No, the Sandiganbayan does not have jurisdiction. The Supreme Court affirmed the Sandiganbayan’s dismissal of the petition for lack of jurisdiction. The Court clarified that the Sandiganbayan is a court of special and limited jurisdiction, its powers confined to those expressly conferred by its charter, Presidential Decree No. 1606, as amended. A scrutiny of the decree reveals no grant of original jurisdiction to the Sandiganbayan over special civil actions for prohibition, mandamus, or quo warranto.
The Court emphasized the fundamental principle that jurisdiction is conferred only by law. Original jurisdiction over petitions for prohibition and mandamus is specifically vested by statute in the Supreme Court, the Court of Appeals, and the Regional Trial Courts. Similarly, original jurisdiction over quo warranto petitions is expressly given to the Supreme Court, the Court of Appeals, and the Regional Trial Courts under Batas Pambansa Blg. 129. In the absence of a specific statutory grant, the Sandiganbayan, as a court of limited jurisdiction, cannot exercise such powers. Since the Sandiganbayan correctly dismissed the petition for lack of jurisdiction, the Court deemed it unnecessary to resolve the ancillary issues regarding the propriety of Garcia’s removal from the UCPB Board.