G.R. No. 255014, August 30, 2023
Presidential Commission on Good Government, Petitioner, vs. C&O Investment and Realty Corp. and Miguel Cojuangco, Respondents.

FACTS

The Presidential Commission on Good Government (PCGG) sequestered a property covered by Transfer Certificate of Title (TCT) No. (T-3034) 018-2018002208, registered in the name of Ramon U. Cojuangco, on May 20, 1986, pursuant to its mandate to recover ill-gotten wealth. The PCGG annotated a sequestration note on the title. Respondents C&O Investment and Realty Corporation (C&O) and its President, Miguel O. Cojuangco, filed a Petition for Nullification/Cancellation of the Letter of Sequestration before the Sandiganbayan. They claimed C&O purchased the property from Spouses Ramon and Imelda Cojuangco in 1976 but failed to transfer the title, only discovering the annotation later. They argued the property, acquired by the Spouses Cojuangco in 1955, could not be ill-gotten as it was obtained long before former President Ferdinand Marcos’s term. The PCGG countered that the action was barred by estoppel and laches, the property was held to answer for dividends from Philippine Telecommunications Investment Corporation (PTIC) shares, sequestration was akin to attachment, and only the Commission En Banc could lift it. The Sandiganbayan granted the petition, lifting the sequestration and ordering the cancellation of the annotation, finding the property not ill-gotten and the sequestration order void for being issued by a PCGG Acting Director without the required authority of at least two Commissioners.

ISSUE

1. Was the subject property validly placed under sequestration?
2. Have estoppel and laches set in warranting the dismissal of the case?
3. Are the respondents the real parties-in-interest?

RULING

1. No, the subject property was not validly placed under sequestration. The PCGG’s mandate covers only ill-gotten wealth. The property was acquired by the Spouses Cojuangco in 1955, a decade before Marcos’s presidency, and thus could not have been acquired through illegal use of government funds. Furthermore, the Letter of Sequestration was issued by the Acting Director of the IRS of the PCGG, not by at least two Commissioners as required by the PCGG’s own Rules and Regulations. Such delegation of quasi-judicial power is invalid, rendering the sequestration void ab initio.
2. No, estoppel and laches did not set in. The PCGG failed to substantiate its claim of estoppel and laches with clear evidence. The respondents’ delay in asserting their rights was justified as they only discovered the sequestration annotation when updating the title for transfer. The State is not immune from laches, but its application requires a clear showing of neglect and injury or prejudice to the public interest, which was not present here.
3. Yes, the respondents are the real parties-in-interest. A real party-in-interest is one who stands to be benefited or injured by the judgment. C&O, as the alleged purchaser of the property per a 1976 Deed of Absolute Sale, and Miguel Cojuangco, as its President and a compulsory heir of the Spouses Cojuangco, have a material interest in the cancellation of the sequestration. The PCGG’s challenge to the deed’s authenticity, being a mere photocopy, was waived as it failed to object to its admissibility during trial, and the document was admitted by the court.
The Supreme Court DENIED the Petition for Review on Certiorari and AFFIRMED the Sandiganbayan’s Decision and Resolution.