G.R. No. 120640 August 8, 1996
Eduardo M. Cojuangco, Jr., et al., petitioners, vs. The Hon. Sandiganbayan, Presidential Commission on Good Government (PCGG), et al., respondents.

FACTS

During the April 18, 1995 annual stockholders’ meeting of San Miguel Corporation (SMC), an election was held for fifteen directors. Private respondents, nominated by the PCGG, were elected after the PCGG voted sequestered SMC shares registered in the nominees’ names to qualify them. Petitioners, also nominees, were not elected. Petitioner Estelito Mendoza protested, arguing that votes he cast representing substantially the same sequestered corporate shares were improperly disregarded by the SMC Corporate Secretary, who ruled that only the PCGG could vote them. Had his votes been counted, he and others claimed they would have been elected.
Petitioners subsequently filed a petition for quo warranto before the Sandiganbayan, seeking to oust the private respondents from the SMC Board for lack of qualifying shares and to declare petitioners as duly elected members in their stead. The Sandiganbayan, First Division, motu proprio dismissed the petition. It relied on the Supreme Court’s ruling in Garcia, Jr. vs. Sandiganbayan, which held that the Sandiganbayan, as a court of special jurisdiction, lacks authority to issue writs of quo warranto absent an express statutory grant. Petitioners filed the instant petition for review.

ISSUE

Whether the Sandiganbayan correctly dismissed the petition for quo warranto for lack of jurisdiction.

RULING

Yes, the Sandiganbayan correctly dismissed the petition. The Supreme Court affirmed the dismissal, upholding the application of the Garcia doctrine. The legal logic is anchored on the principle that jurisdiction over special civil actions like quo warranto must be expressly conferred by law. The Sandiganbayan’s jurisdiction, defined by Presidential Decree No. 1606, as amended, is special and limited to cases involving public officers and employees falling within its specific statutory grant. While the Court acknowledged its prior rulings in cases like Soriano III vs. Yuzon, which recognized Sandiganbayan jurisdiction over incidents related to PCGG cases, it clarified that such jurisdiction is not plenary. The Garcia ruling explicitly settled that no law grants the Sandiganbayan original jurisdiction to issue writs of quo warranto. The present case, being a direct petition for quo warranto challenging corporate elections, falls squarely under this prohibition. The fact that the case involves sequestered shares and PCGG actions does not automatically vest jurisdiction, as the core action remains a quo warranto proceeding over which the Sandiganbayan has no power. The Court found no reversible error in the Sandiganbayan’s order.