GR 154522; (May, 2006) (Digest)
G.R. No. 154522 , G.R. No. 154694, G.R. No. 155554, G.R. No. 155711. May 5, 2006.
Republic of the Philippines, Represented by the Anti-Money Laundering Council, Petitioner, vs. Various Corporate and Individual Respondents.
FACTS
The Anti-Money Laundering Council (AMLC) issued freeze orders against various bank accounts of the respondents, having found them prima facie related to unlawful activities. Under the original Republic Act No. 9160 (Anti-Money Laundering Act of 2001), such an order was effective for a maximum of 15 days but could be extended “upon order of the court.” Before the initial periods lapsed, the AMLC filed petitions with the Court of Appeals (CA) seeking extensions, believing the CA had jurisdiction to grant them. The CA uniformly dismissed the petitions, ruling that RA 9160 did not vest it with the power to extend a freeze order issued by the AMLC.
While these consolidated petitions were pending before the Supreme Court, Congress enacted RA 9194, which amended RA 9160. The new law explicitly provided that the Court of Appeals, upon ex parte application by the AMLC, may issue a freeze order effective immediately for twenty days “unless extended by the court.” A transitory provision further stated that existing AMLC freeze orders remained in force for 30 days after the effectivity of the new act, “unless extended by the Court of Appeals.” Following this amendment, the Office of the Solicitor General moved to remand the cases to the CA.
ISSUE
Which court has jurisdiction to extend the effectivity of a freeze order issued under the Anti-Money Laundering Act?
RULING
The Supreme Court ruled that jurisdiction is vested exclusively in the Court of Appeals. The enactment of RA 9194 during the pendency of these petitions resolved the legal ambiguity. The amendatory law clearly states that the Court of Appeals may issue a freeze order and, significantly, may also extend its effectivity. The transitory provision of RA 9194 likewise explicitly grants the CA authority to extend existing freeze orders previously issued by the AMLC.
Consequently, the legal logic is straightforward: the new statute expressly confers the power of extension upon the CA, thereby superseding any prior interpretation of the original law’s vague phrase “upon order of the court.” Given that one of the consolidated cases (G.R. No. 154694) had already become moot due to the CA granting an extension under the new law, the Supreme Court dismissed it. The remaining cases were remanded to the Court of Appeals for appropriate action under the clear mandate of RA 9194. A previously issued temporary restraining order was maintained pending the CA’s resolution.
