GR 135789; (January, 2002) (Digest)
G.R. No. 135789 ; January 31, 2002
REPUBLIC OF THE PHILIPPINES, represented by the PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT, petitioner, vs. SANDIGANBAYAN (Fourth Division), ESTATE OF HANS M. MENZI (through its Executor, MANUEL G. MONTECILLO), and HANS MENZI HOLDINGS AND MANAGEMENT, INC. (HMHMI), respondents.
FACTS
The Presidential Commission on Good Government (PCGG) issued a writ of sequestration on February 12, 1987, against all assets and shares of Hans M. Menzi Holdings and Management, Inc. (HMHMI). The PCGG alleged HMHMI served as a holding company for shares owned by the late Hans M. Menzi and his associates, including Eduardo Cojuangco, Jr., in Bulletin Publishing Corporation and other firms, implying these were ill-gotten wealth. The PCGG filed a corresponding judicial action (Civil Case No. 0022) but initially did not implead HMHMI as a defendant.
The Estate of Hans M. Menzi, on behalf of HMHMI, moved to lift the sequestration, arguing it was issued without a judicial action filed against HMHMI within the constitutional reglementary period. The Sandiganbayan, upon Supreme Court remand to determine if a prima facie factual basis existed for the sequestration, resolved the preliminary question. In its April 13, 1998 Resolution, it found no such prima facie basis and ordered the writ lifted, a decision it reaffirmed on August 21, 1998.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in ruling that there was no prima facie factual basis for the issuance of the writ of sequestration over HMHMI’s assets.
RULING
The Supreme Court denied the petition. The core issue raised by the PCGG was factual, not legal. The Court’s appellate jurisdiction over Sandiganbayan decisions is confined to questions of law. A question of law exists when the dispute centers on the application of legal principles to admitted or established facts. In contrast, a question of fact arises when the doubt pertains to the truth or falsehood of alleged facts and requires an examination of the evidence’s probative value. The determination of whether prima facie evidence supports a sequestration writ necessitates evaluating the submitted evidence’s weight and credibility, which is inherently a factual inquiry.
The Court, not being a trier of facts, defers to the Sandiganbayan’s factual findings absent a showing of grave abuse of discretion. The Sandiganbayan, based on the evidence presented, found that the late Hans M. Menzi had owned Bulletin Publishing Corporation since 1957 and that the PCGG failed to competently demonstrate that President Ferdinand Marcos or his cronies had ever acquired Menzi’s or HMHMI’s shares to warrant sequestration. The petitioner did not successfully prove that the Sandiganbayan’s assessment was capricious or whimsical. Consequently, the Court upheld the resolutions lifting the sequestration and directed the Sandiganbayan to proceed with the expeditious disposition of the main case.