GR 86926; (October, 1991) (Digest)
G.R. No. 86926 and G.R. No. 86949, October 15, 1991
CESAR E. A. VIRATA and PLACIDO L. MAPA, petitioners, vs. THE HONORABLE SANDIGANBAYAN, and THE REPUBLIC OF THE PHILIPPINES, respondents.
FACTS
The Republic of the Philippines, through the Presidential Commission on Good Government (PCGG), filed Civil Case No. 0035 before the Sandiganbayan for the recovery of alleged ill-gotten wealth amassed during the Marcos regime. Petitioners Cesar Virata and Placido Mapa, former government officials, were among the numerous defendants impleaded. They filed separate motions to dismiss the Second Amended Complaint on multiple grounds, including failure to state a cause of action, lack of authority of the PCGG and Solicitor General to file and prosecute the case, and alleged unconstitutionality of the PCGG’s charter as a bill of attainder, an ex post facto law, and for violating equal protection. The Sandiganbayan denied these motions and the subsequent motions for reconsideration. Aggrieved, petitioners filed these consolidated petitions for certiorari and prohibition, seeking to annul the Sandiganbayan’s resolutions and to halt the proceedings.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in denying the motions to dismiss the complaint for recovery of ill-gotten wealth.
RULING
The Supreme Court dismissed the petitions, finding no grave abuse of discretion by the Sandiganbayan. On the sufficiency of the cause of action, the Court ruled that a motion to dismiss hypothetically admits the truth of the material allegations in the complaint. The test is whether, admitting those facts, the court can render a valid judgment. The detailed allegations in the complaint regarding specific acts allegedly constituting unlawful accumulation of wealth sufficiently stated causes of action, making any factual disputes proper for a full trial. Regarding the authority to sue, the Court held that the PCGG, created under the Provisional Constitution, was expressly tasked with recovering ill-gotten wealth, and the Solicitor General, under its statutory mandate, could represent the Republic in such suits. The constitutional creation of the Office of the Ombudsman did not automatically divest the PCGG and Solicitor General of their existing authority. The constitutional challenges against the PCGG’s charter were also rejected. The Court ruled that Executive Orders creating the PCGG were not bills of attainder, as they did not impose punishment without judicial trial, nor were they ex post facto laws, which pertain only to criminal matters, not civil recovery. The classification for investigating wealth accumulated under the previous administration was held to be based on substantial distinctions and not violative of equal protection.