GR 183446; (November, 2012) (Digest)
G.R. No. 183446 , November 13, 2012
Republic of the Philippines, Petitioner, vs. Estate of Hans Menzi (Through Its Executor, Manuel G. Montecillo), Sandiganbayan (Fourth Division) and Sheriffs Reynaldo Melquiades and Albert A. Dela Cruz, Respondents.
FACTS
The Presidential Commission on Good Government (PCGG) sequestered shares in Bulletin Publishing Corporation and assets of Hans Menzi Holdings and Management, Inc. (HMHMI), alleging they were ill-gotten wealth linked to former President Ferdinand Marcos. The Republic filed Civil Case No. 0022 for reconveyance. In a related Supreme Court case (G.R. No. 79126), the Court in 1988 ordered that a cash deposit from Bulletin for certain shares be held, subject to alternative conditions: it would either pay for the shares if the Republic was declared owner, or be returned if the registered owner was declared the true owner. The Sandiganbayan later lifted the sequestration over HMHMI assets, a decision affirmed by the Supreme Court in 2002 ( G.R. No. 135789 ), finding no factual basis for the sequestration. Following this final judgment, the Estate of Hans Menzi moved for the release of the cash deposit.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in ordering the release of the cash deposit to the Estate of Hans Menzi.
RULING
No. The Sandiganbayan did not commit grave abuse of discretion. The legal logic is anchored on the doctrine of conclusiveness of judgment and the specific terms of the Supreme Court’s 1988 ruling in G.R. No. 79126. The 2002 Supreme Court decision in G.R. No. 135789 , which became final and executory, definitively ruled that the sequestration of HMHMI assets was without factual basis. This judgment conclusively settled the issue of ownership over the assets linked to HMHMI, including the shares underlying the cash deposit. Consequently, the alternative condition in the 1988 ruling was triggered: the cash deposit must be returned to the registered owner of the shares, as the Republic failed to secure a final judgment declaring it the owner. The Sandiganbayan’s order to release the deposit to the Estate was a logical and correct execution of these final judgments. The Republic’s petition, which essentially sought to re-litigate the ownership issue already settled with finality, was without merit. Certiorari requires a showing of capricious or whimsical exercise of judgment, which was absent as the Sandiganbayan merely enforced the legal consequences of existing final decisions.