GR 140615; (February, 2001) (Digest)
G.R. No. 140615 . February 19, 2001.
Republic of the Philippines, represented by the Presidential Commission on Good Government (PCGG), petitioner, vs. The Sandiganbayan (Second Division) and Rodolfo T. Arambulo, respondents.
FACTS
The PCGG sequestered shares in Piedras Petroleum Co., Inc., registered in the names of seven individuals, including private respondent Rodolfo Arambulo, alleging they were nominees of Roberto Benedicto and funded with ill-gotten wealth from Imelda Marcos. In Civil Case No. 0034, the Republic and Benedicto entered into a Compromise Agreement, subsequently approved by the Sandiganbayan, wherein Benedicto ceded certain assets to the government. Arambulo was not a party to this agreement. Arambulo filed a Motion for Execution, claiming his 1/7 Piedras shares were excluded from the ceded assets in the Compromise Agreement and thus remained his property. He sought a declaration of ownership and payment for dividends.
The Sandiganbayan granted Arambulo’s motion through its July 11, 1997 Resolution, declaring him the owner of the shares and ordering the payment of dividends. The PCGG moved for reconsideration, arguing Arambulo failed to prove legitimate acquisition of the shares and that the funds originated from a Marcos account. The Sandiganbayan denied the motion, prompting the PCGG to file this petition, alleging grave abuse of discretion and lack of jurisdiction.
ISSUE
Did the Sandiganbayan commit grave abuse of discretion in declaring Arambulo the owner of the Piedras shares and awarding him dividends based on a motion for execution of a judgment to which he was not a party?
RULING
No, the Sandiganbayan did not commit grave abuse of discretion. The Court upheld the Sandiganbayan’s resolutions. The legal logic is anchored on the nature of the Compromise Agreement and the burden of proof. The Sandiganbayan correctly ruled that the Compromise Agreement, a contract between the Republic and Benedicto, could only bind the parties thereto. Since Arambulo was not a party, the agreement could not adjudicate his property rights. His shares were not listed among the assets ceded by Benedicto to the government.
Consequently, the presumption of regularity of the stock registration in Arambulo’s favor stood. The burden to prove the shares were ill-gotten and thus owned by the government rested on the PCGG. The Sandiganbayan found the PCGG’s evidence insufficient. The allegation that the subscription was funded by a check from an Imelda Marcos account was not substantiated with proof that the account was indeed hers. The Sandiganbayan’s factual findings, being supported by evidence, are conclusive on the Supreme Court. Therefore, the Sandiganbayan acted within its jurisdiction in granting affirmative relief to Arambulo via the execution proceeding to enforce his rights unaffected by the compromise.