GR 88345; (February, 1996) (Digest)
G.R. No. 88345 ; February 1, 1996
First Philippine Holdings Corporation, petitioner, vs. Hon. Sandiganbayan, Republic of the Philippines, Benjamin (Kokoy) Romualdez, Juliette Gomez Romualdez, Trans Middle East (Phils.) Equities, Inc., and Edilberto S. Narciso, Jr., respondents.
FACTS
The Presidential Commission on Good Government (PCGG) filed Civil Case No. 0035 before the Sandiganbayan, seeking the reconveyance of 6,299,177 sequestered PCIBank shares as alleged ill-gotten wealth of respondent Benjamin “Kokoy” Romualdez. The PCGG claimed these shares were acquired by Romualdez through dummies, respondents Trans Middle East (Phils.) Equities, Inc. and Edilberto S. Narciso, Jr., in violation of the Anti-Graft and Corrupt Practices Act. The Sandiganbayan had previously allowed Equities to intervene, asserting ownership of the shares.
Petitioner First Philippine Holdings Corporation (FPHC) filed a Motion for Leave to Intervene, alleging it was the original owner of the shares. FPHC claimed the shares were sold to Romualdez’s dummies under a void or voidable 1984 Sale of Stocks and Escrow Agreement due to fraud, breach of fiduciary duty, and a grossly inadequate price. FPHC prayed for the return of the shares. The Sandiganbayan denied the motion, ruling that FPHC’s claim was a personal, intra-corporate controversy outside its jurisdiction and that intervention would delay the proceedings.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in denying FPHC’s motion for leave to intervene.
RULING
Yes. The Supreme Court granted the petition, reversing the Sandiganbayan’s resolutions. The Court held that the Sandiganbayan gravely abused its discretion in denying intervention. Under Rule 12, Section 2 of the Rules of Court, a person has a right to intervene if they have a legal interest in the matter in litigation. FPHC’s claim of direct ownership over the very shares subject to the forfeiture suit constitutes a sufficient legal interest. A judgment in the main case favoring the Republic would effectively dispose of the property FPHC claims to own, directly prejudicing its rights.
The Sandiganbayan’s assertion that the claim was an intra-corporate matter beyond its jurisdiction was erroneous. The Court, citing precedents like Republic vs. Sandiganbayan (Peña), clarified that the Sandiganbayan’s exclusive jurisdiction over PCGG cases includes the authority to resolve incidents affecting sequestered properties, such as claims of ownership by third parties like FPHC. Denying intervention would deprive FPHC of a legal remedy to recover property allegedly taken illegally. While intervention is generally discretionary, mandamus lies when denial amounts to gross abuse of discretion, manifest injustice, or a palpable excess of authority, as in this case. The Sandiganbayan was directed to grant FPHC’s motion and admit its complaint in intervention.