GR 84895; (May, 1989) (Digest)
G.R. No. 84895 May 4, 1989
REPUBLIC OF THE PHILIPPINES and JOSE D. CAMPOS, JR., petitioner-intervenor, vs. THE HONORABLE SANDIGANBAYAN, FIRST DIVISION, TEODORO Q. PEÑA, GORGONIO MACARIOLA, ORLANDO PACIENCIA, JESUS TUPALAR, SEVERINO DELA CRUZ, and FE CORTEZO, respondents.
FACTS
The Republic, through the Presidential Commission on Good Government (PCGG), filed Civil Case No. 0010 before the Sandiganbayan to recover alleged ill-gotten wealth accumulated during the Marcos regime. Among the numerous defendants was Jose D. Campos, Jr. Subsequently, both the Republic and Campos, Jr. filed motions to drop him as a defendant. Their primary ground was a PCGG Resolution dated May 28, 1986, which granted immunity to Jose Y. Campos and his family from suit, a grant they argued extended to his son, Jose D. Campos, Jr. The Republic asserted that this immunity was part of a compromise to expedite the recovery of assets.
Private respondents, who are co-defendants in the civil case, opposed the motions. The Sandiganbayan denied them, reasoning that the PCGG lacked the power to grant civil immunity, the scope of the immunity was unclear regarding the specific transactions involving Campos, Jr., and there was no showing that the claims against him had been extinguished aside from the alleged immunity.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in denying the motions to drop Jose D. Campos, Jr. as a defendant based on the PCGG-granted immunity.
RULING
Yes, the Sandiganbayan committed grave abuse of discretion. The Supreme Court granted the petition, reversed the Sandiganbayan’s resolutions, and ordered the dropping of Campos, Jr. as a defendant. The legal logic centered on the nature of the PCGG’s powers and the principle of party autonomy in civil actions.
First, the Court clarified that the PCGG, acting as the government’s agent, possesses the authority to enter into compromises, including grants of immunity, to fulfill its mandate of recovering ill-gotten wealth. Such compromises are judicially encouraged to avoid protracted litigation. The grant to Jose Y. Campos and his family constituted a valid compromise agreement, binding upon the Republic. Since Jose D. Campos, Jr. is indisputably a family member, the immunity extends to him.
Second, the Sandiganbayan’s role is adjudicative, not supervisory, over the PCGG’s prosecutorial decisions. The Republic, as the plaintiff, retains control over whom to sue. Its decision to drop a defendant, especially when based on a compromise intended to benefit the government by facilitating asset recovery, should be respected absent a clear showing of grave abuse. The Court found no such abuse here; the move was a strategic exercise of the State’s prerogative.
Finally, the opposition from private respondents, who are co-defendants, was deemed without legal prejudice. Their liability, if any, is several and not automatically affected by the discharge of one co-defendant in a civil action for recovery. The ruling ensures the compromise is effectuated, allowing the government to pursue its primary objective of asset recovery efficiently.