GR 116463; (June, 2003) (Digest)
G.R. No. 116463; June 10, 2003
Republic of the Philippines (DPWH) vs. Court of Appeals, Hon. Amanda Valera-Cabigao, and Navotas Industrial Corporation
FACTS
Private respondent Navotas Industrial Corporation (NIC) filed a complaint for sum of money against the Republic, through the DPWH, before the Regional Trial Court (RTC) of Malabon. NIC alleged it performed dredging work under four contracts with the DPWH but was underpaid by ₱30,799,676.00. The DPWH, in its answer and counterclaim, contended the contracts were void for being awarded without public bidding and that NIC, in connivance with DPWH officials, falsified documents to collect payment for work not actually performed. The DPWH sought the return of ₱146,962,072.47.
Subsequently, the Ombudsman filed criminal Informations for estafa through falsification and violations of the Anti-Graft and Corrupt Practices Act (R.A. No. 3019) against the involved DPWH officials and NIC’s president before the Sandiganbayan. The DPWH then filed a Motion in the RTC to consolidate the civil case with the pending criminal cases in the Sandiganbayan, arguing they arose from the same facts. The RTC denied the motion, a decision affirmed by the Court of Appeals, prompting the DPWH’s petition to the Supreme Court.
ISSUE
Whether the civil case for collection of sum of money filed by NIC in the RTC should be consolidated with the related criminal cases pending before the Sandiganbayan.
RULING
No. The Supreme Court denied the petition and affirmed the rulings of the lower courts. The legal logic rests on the distinct jurisdictions of the RTC and the Sandiganbayan, and the nature of the civil liability sought. The Sandiganbayan’s jurisdiction, under P.D. No. 1606, as amended, is limited to criminal cases involving specific offenses like violations of R.A. No. 3019 and the civil liability arising ex delicto from those crimes. The civil case filed by NIC is an independent civil action for the collection of a sum of money based on contract, not an action for civil liability arising from the criminal offenses charged.
Consolidation is not legally permissible because the Sandiganbayan lacks jurisdiction to hear and decide NIC’s independent civil action for collection. The purpose of consolidation—to avoid multiplicity of suits and conflicting decisions—cannot be achieved, as the Sandiganbayan could not adjudicate NIC’s contractual claim. Furthermore, the DPWH’s counterclaim for the return of paid amounts, being inherently connected to the criminal charges of fraud and graft, is a civil liability arising from the crime and thus falls within the Sandiganbayan’s jurisdiction to resolve in the criminal cases. Therefore, the two actions must proceed separately in their respective competent courts.