GR 81385; (February, 1989) (Digest)
G.R. No. 81385 February 21, 1989
Eduardo B. Olaguer and Conrado S. Reyes, in their official capacity as Fiscal Agents of the Presidential Commission on Good Government, petitioners, vs. The Regional Trial Court, National Capital Judicial Region, Branch 48, Manila, Presided by the Honorable Judge Demetrio M. Batario, Jr., et al., respondents.
FACTS
Private respondents, claiming to be the legitimate voting stockholders of Philippine Journalists, Inc. (PJI), filed a complaint for injunction and damages in the Regional Trial Court (RTC) of Manila. They sought to restrain petitioners Eduardo Olaguer and Conrado Reyes, who were acting as corporate officers of PJI, from conducting a special stockholders’ meeting and exercising control. The complaint alleged that Olaguer, originally a DBP proxy on the PJI board, had been terminated from DBP but continued to control PJI by claiming authority as a fiscal agent of the Presidential Commission on Good Government (PCGG). Private respondents argued that Olaguer and his associates were usurpers without proper stockholder election or qualifying shares.
The core dispute centered on corporate control of PJI, a publisher sequestered by the PCGG. Petitioners, as PCGG fiscal agents, asserted that the Sandiganbayan had exclusive jurisdiction over the matter because PJI was among the corporations involved in a case (Civil Case No. 0035) pending before that anti-graft court. They argued that the RTC had no authority to interfere, as the suit implicated acts performed under the PCGG’s sequestration mandate.
ISSUE
Whether the Regional Trial Court has jurisdiction over the complaint for injunction and damages against PCGG fiscal agents concerning the management and control of a sequestered corporation.
RULING
The Supreme Court ruled that the RTC had no jurisdiction; exclusive jurisdiction vested in the Sandiganbayan. The legal logic is anchored on the jurisdictional delineation established by Presidential Decree No. 1606, as amended, and the nature of the PCGG’s functions. The Sandiganbayan is vested with exclusive original jurisdiction over all cases involving the recovery of ill-gotten wealth and related matters, including suits concerning sequestered corporations. Since PJI was under sequestration and listed in a pending Sandiganbayan case, any dispute regarding its management and control directly fell within that court’s purview.
Furthermore, the petitioners were sued in their official capacity as PCGG fiscal agents. Executive Order No. 1 grants the PCGG and its members immunity from suit for damages for acts done in the discharge of its tasks. The complaint, though framed as an injunction suit, ultimately challenged the PCGG agents’ authority over a sequestered asset, a matter intrinsically linked to the Commission’s mandate. Therefore, the ordinary courts could not adjudicate the issues raised, which properly pertained to the Sandiganbayan. The Court made the restraining order permanent, lifted its own interim order, and directed the dismissal of the RTC complaint for lack of jurisdiction.