G.R. No. 199031 , October 10, 2022
BLEMP COMMERCIAL OF THE PHILIPPINES, INC., PETITIONER, VS. THE HON. SANDIGANBAYAN FIRST DIVISION, PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT, ORTIGAS & COMPANY LIMITED PARTNERSHIP, RICARDO C. SILVERIO, AND MID-PASIG LAND DEVELOPMENT CORPORATION, RESPONDENTS. (Consolidated with G.R. Nos. 199053, 199058, 204368, 204373, 204604, 204612, 214658, 221729, and 253735)

FACTS

Ortigas & Company Limited Partnership (Ortigas) owned a prime 16-hectare property in Pasig. It alleged that in 1968, then President Ferdinand Marcos and his wife Imelda demanded the donation of the property for their personal use. When Ortigas’s Board refused, President Marcos allegedly threatened to use his powers to harass the corporation and its officers. Out of fear, Ortigas executed a Deed of Conditional Sale, selling the property at a low price to Maharlika Estate Corporation, a Marcos nominee. The rights were later transferred to Mid-Pasig Land Development Corporation, also alleged to be a Marcos dummy. After the 1986 EDSA Revolution, the titles were surrendered to the government and placed under the control of the Presidential Commission on Good Government (PCGG).
Ortigas filed a complaint before the Sandiganbayan seeking to annul the deeds and titles, arguing the sale was void due to intimidation and vitiated consent. Ricardo Silverio, representing Anchor Estate (formerly Maharlika), filed a separate complaint claiming ownership, having fully paid Ortigas, and assailing the fraudulent transfer to Mid-Pasig. The cases were consolidated. The Sandiganbayan dismissed Ortigas’s complaint and partially granted PCGG’s motion for summary judgment. Multiple petitions were filed before the Supreme Court assailing the Sandiganbayan’s resolutions and decision.

ISSUE

Whether the Sandiganbayan correctly dismissed Ortigas’s complaint for annulment of the deeds of sale, finding insufficient evidence to prove that the contracts were executed under intimidation rendering Ortigas’s consent void.

RULING

Yes, the Supreme Court affirmed the Sandiganbayan’s dismissal. The Court emphasized that contracts are presumed valid and regular, and the party impugning a contract bears the burden of proving vitiated consent by clear and convincing evidence. For intimidation to nullify consent, it must be of such gravity as to overcome a person of ordinary firmness, and the details of how it was exerted must be clearly established.
The Court found Ortigas’s evidence lacking. The alleged threat by President Marcos was general and not sufficiently detailed. Ortigas failed to present specific evidence on how the threat was communicated, its exact nature, or how it overpowered the will of its officers. The long interval between the alleged 1968 threat and the execution of subsequent agreements in the 1970s, without further documented protest or action by Ortigas, undermined its claim of continuous coercion. Furthermore, Ortigas accepted payments and performed acts consistent with a valid contract over many years. These circumstances did not overcome the legal presumption of the contract’s validity. The Court held that mere allegations of intimidation, without clear and convincing proof of its gravity and causal connection to the execution of the contracts, are insufficient to declare a contract void.