GR 85284; (February, 1990) (Digest)
G.R. No. 85284 February 28, 1990
REPUBLIC OF THE PHILIPPINES, petitioner, vs. SANDIGANBAYAN (Third Division), SIMPLICIO A. PALANCA, et al., respondents.
FACTS
The Presidential Commission on Good Government (PCGG) filed Civil Case No. 0025 before the Sandiganbayan against Ferdinand E. Marcos and others for the recovery of alleged ill-gotten wealth. The complaint included properties listed under “BREDCO LOTS” and shares of stock in Bacolod Real Estate Development Corporation (BREDCO). Private respondent Simplicio A. Palanca, on behalf of himself and other BREDCO stockholders, filed a Motion for Leave to Intervene with an attached Answer in Intervention. They alleged a legal interest in the BREDCO properties, arguing that the titles to the lots were registered in BREDCO’s name, not the defendants’, and that the shares were held by Marsteel Consolidated Inc. under circumstances they detailed.
The petitioner Republic, through the Solicitor General, opposed the intervention and moved to dismiss the Answer in Intervention. The Sandiganbayan granted the motion to intervene and admitted the Answer. The Republic’s motion for reconsideration was denied, prompting this petition for certiorari, prohibition, and mandamus. The Republic argued that the intervention was a suit against the state without its consent, that the Sandiganbayan lacked jurisdiction over the intervenors’ claims, and that the intervenors had no legal interest in the litigation.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in granting the private respondents’ motion to intervene in Civil Case No. 0025.
RULING
The Supreme Court dismissed the petition, upholding the Sandiganbayan’s resolution. The Court ruled that the intervention was proper under the Rules of Court, which allow a person with a legal interest in the matter in litigation to intervene to protect that interest. The private respondents, as stockholders, sufficiently demonstrated a direct interest in the BREDCO properties subject to the Republic’s claim for reconveyance.
Crucially, the Court held that the intervention did not constitute a suit against the state requiring its consent. The private respondents did not file a complaint or seek affirmative relief against the Republic. They merely sought to join the defendants in resisting the Republic’s claims, occupying a purely defensive position to exclude the BREDCO assets from any judgment. An intervention of this nature, which unites with a defendant to oppose the plaintiff’s demand, is not considered a counter-suit against the sovereign. Since the intervenors asked for no affirmative relief against the state, the doctrine of state immunity from suit was not violated. The Sandiganbayan did not act without or in excess of jurisdiction or with grave abuse of discretion in allowing the intervention to proceed.