G.R. No. 78750; April 20, 1990
THE PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT, petitioner, vs. HON. JOSE V. NEPOMUCENO as Presiding Judge, Regional Trial Court, 5th Judicial Region, Branch 23, Naga City and PHILIPPINE RADIO CORPORATION, respondents.

FACTS

The Presidential Commission on Good Government (PCGG) sequestered Radio Station DWRN, operated by the Philippine Radio Corporation (PRC), on April 18, 1986, based on prima facie evidence that it was part of alleged ill-gotten wealth. The PCGG later issued a take-over order on October 14, 1986, after discovering that the station manager was concealing properties and refusing to cooperate, which led to a personnel boycott that forced the station off the air. In response, PRC filed a civil case before the Regional Trial Court (RTC) of Naga City, seeking to declare the sequestration and subsequent take-over as illegal and to restrain the PCGG’s actions. The RTC, presided by Judge Jose V. Nepomuceno, assumed jurisdiction and issued a writ of preliminary injunction against the PCGG.

ISSUE

Whether the Regional Trial Court has jurisdiction to interfere with or restrain the orders and actions of the PCGG regarding sequestered properties.

RULING

The Supreme Court ruled that the RTC has no jurisdiction. The legal logic is anchored on the exclusive jurisdiction granted to the Sandiganbayan over all cases involving the recovery of ill-gotten wealth and related incidents, as expressly provided under Executive Order No. 14, as amended. The Court emphasized that the PCGG’s powers, including sequestration and take-over, are exercised pursuant to its mandate under Executive Orders Nos. 1, 2, and 14, which have been previously upheld as constitutional. Any challenge to the propriety of these acts, including allegations of irregularity in their implementation, falls within the sole competence of the Sandiganbayan. This allocation of jurisdiction is designed to prevent conflicting decisions and ensure a unified, specialized approach to handling ill-gotten wealth cases. Consequently, the RTC’s assumption of jurisdiction and issuance of the injunction constituted grave abuse of discretion for acting without authority. The Court also addressed and rejected PRC’s claim that the take-over violated constitutional freedoms of speech and the press, clarifying that the PCGG’s actions were preservation measures, not censorship. The writs of certiorari and prohibition were granted, the RTC orders were set aside, and the case was ordered dismissed for lack of jurisdiction.