GR 89425; (February, 1992) (Digest)
G.R. No. 89425 . February 25, 1992. REPUBLIC OF THE PHILIPPINES (represented by the Presidential Commission on Good Government), petitioner, vs. SANDIGANBAYAN, Second Division, and REBECCO PANLILIO, respondents.
FACTS
The Presidential Commission on Good Government (PCGG) sequestered Silahis International Hotel and other corporations in 1986. In 1987, the PCGG filed a case with the Sandiganbayan for reversion and reconveyance of these allegedly ill-gotten assets. In July 1989, citing labor unrest and a need to protect government interest, the PCGG issued a Mission Order creating a Management Committee to take over the hotel’s operations. Rebecco Panlilio, a defendant in the main case, filed a motion for injunction with the Sandiganbayan to stop the takeover. He argued the hotel was profitable and the labor dispute was being negotiated, rendering the PCGG’s action a baseless overreach of its conservatory powers.
The Sandiganbayan granted Panlilio’s motion, enjoining the PCGG from implementing the Mission Order. It found that Panlilio presented evidence of the hotel’s viability, while the PCGG’s sole justification was the labor situation, which did not constitute a dissipation of assets warranting a management takeover. The PCGG challenged this resolution via certiorari, asserting that the Sandiganbayan had no jurisdiction to review its administrative and conservatory acts, such as the issuance of the Mission Order, and that the anti-graft court had committed grave abuse of discretion.
ISSUE
Whether the Sandiganbayan committed grave abuse of discretion in enjoining the PCGG’s implementation of its Mission Order for the takeover of the sequestered hotel’s management.
RULING
No, the Sandiganbayan did not commit grave abuse of discretion. The Supreme Court dismissed the PCGG’s petition. The Court clarified the jurisdictional interplay: while the PCGG has primary administrative jurisdiction to issue sequestration and takeover orders, the Sandiganbayan retains the power to review these acts to determine if they were exercised within the legal bounds of the PCGG’s authority as a conservator. Executive Orders did not intend to make the PCGG’s acts unreviewable or to convert it into an entity with absolute power over sequestered properties.
The Sandiganbayan’s review was proper. Its finding that the PCGG’s takeover was not justified by evidence of asset dissipation—the only valid ground for such an intrusive conservatory act—was based on its evaluation of the evidence presented by both parties. The PCGG’s reliance on labor unrest alone was insufficient. An error in judgment, if any, in weighing evidence does not equate to grave abuse of discretion, which implies a capricious, whimsical, or arbitrary exercise of judgment. The Sandiganbayan acted within its jurisdiction to prevent a potential violation of rights not justified by tenable grounds, and its decision was supported by the evidence on record.