GR 140301; (April, 2005) (Digest)
G.R. No. 140301 . April 26, 2005
PAUL C. DEL MORAL, JUAN ANTONIO DEL MORAL and JOSE LUIS C. DEL MORAL, Petitioners, vs. REPUBLIC OF THE PHILIPPINES Represented by the Presidential Commission on Good Government (PCGG) and the Sandiganbayan, Respondents.
FACTS
The Presidential Commission on Good Government (PCGG) sequestered Mountain View Real Estate Corporation in 1986, alleging its assets were ill-gotten wealth. In 1987, petitioners, co-owners of a parcel of land with Mountain View, filed an action for partition before the Regional Trial Court (RTC) of Tagaytay City. Mountain View was declared in default. The RTC rendered a decision in 1988 approving a project of partition, allocating a specific area to Mountain View. This decision was later amended, reducing Mountain View’s allocated share.
The Republic, through PCGG, learned of the partition case only in 1994. In 1996, it filed a petition before the Sandiganbayan seeking to annul the RTC’s amended decision and for reconveyance of the reduced area to Mountain View. Petitioners moved to dismiss, arguing the Sandiganbayan lacked jurisdiction over a petition to annul an RTC decision.
ISSUE
Whether the Sandiganbayan has jurisdiction to annul a decision of a Regional Trial Court in a partition case involving a sequestered corporation alleged to hold ill-gotten wealth.
RULING
Yes, the Sandiganbayan has jurisdiction. The Supreme Court upheld the Sandiganbayan’s denial of the motion to dismiss. The legal logic rests on the expansive jurisdiction granted to the Sandiganbayan over cases for the recovery of ill-gotten wealth under Presidential Decree No. 1606, as amended. This jurisdiction extends to all incidents “arising from, incidental to, or related to” such cases, as established in PCGG vs. Peña.
The core of the dispute—Mountain View’s share in the partitioned property—was a sequestered asset listed in a separate ill-gotten wealth case against its president. The PCGG’s petition for annulment and reconveyance is directly related to preserving and recovering that specific asset for the government. The fact that the government’s ownership via a compromise agreement was formalized in 1992, after the RTC’s 1988 amended decision, is immaterial. The asset was under sequestration and subject to recovery proceedings at the time of the RTC action. Allowing the RTC decision to stand would directly affect the res (the property) involved in the ill-gotten wealth case. Therefore, the Sandiganbayan correctly assumed jurisdiction to prevent a lower court’s decision from undermining its exclusive authority over the sequestered property integral to the main recovery case. The petition was dismissed for lack of merit.