GR 130716; (May, 1999) (Digest)
G.R. No. 130716. May 19, 1999
FRANCISCO I. CHAVEZ, petitioner, vs. PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT (PCGG) and MAGTANGGOL GUNIGUNDO, respondents, GLORIA A. JOPSON, et al., petitioners-in-intervention.
FACTS
The Supreme Court, in its Decision dated December 9, 1998, declared the 1993 General and Supplemental Agreements between the PCGG and the Marcos heirs null and void for being contrary to law and the Constitution. The Agreements aimed to settle claims over alleged ill-gotten wealth. Following this final and executory Decision, Ma. Imelda Marcos-Manotoc, Ferdinand R. Marcos II, and Irene Marcos-Araneta (movants) filed a Motion for Leave to Intervene and a Partial Motion for Reconsideration on January 22, 1999. They claimed a legal interest as parties and signatories to the voided Agreements and argued that their exclusion from the original petition led to a denial of due process and equal protection.
ISSUE
The primary issues were: (1) whether the motion for intervention could be granted after the judgment had become final and executory; and (2) whether the movants were denied due process by not being made parties to the original case.
RULING
The Court denied the motions. First, intervention is no longer permissible after a final judgment. Under Section 2, Rule 19 of the Rules of Court, a motion to intervene must be filed before the rendition of judgment. The Court’s Decision was promulgated on December 9, 1998, and the movants filed only in January 1999, without a valid excuse for the delay. The judgment had become final as the original parties did not seek reconsideration.
Second, there was no denial of due process. The movants were not indispensable parties to the original petition filed by Francisco Chavez, which was a taxpayer’s suit questioning the constitutionality and legality of the PCGG’s acts. The Court emphasized that the Agreements were void ab initio for violating constitutional and statutory provisions; such nullity affected everyone and was not contingent on the participation of specific contractors. A void contract produces no legal effects and vests no rights. Since the Court’s adjudication focused on the PCGG’s authority and the agreements’ invalidity as a matter of public law, the movants’ contractual interests were merely incidental. The Court further noted it had already substantively addressed the arguments raised in their motions, thus affording them a hearing on the merits. Consequently, their claims of due process and equal protection violations were without basis.