G.R. No. 92422 . May 23, 1991. AMERICAN INTER-FASHION CORPORATION, petitioner, vs. OFFICE OF THE PRESIDENT, GARMENTS & TEXTILE EXPORT BOARD & GLORIOUS SUN FASHION GARMENTS MANUFACTURING CO. (PHILS.), INC., respondents.
FACTS

This case originated from a 1984 ruling of the Garments and Textile Export Board (GTEB) finding respondent Glorious Sun guilty of misdeclaration of imported raw materials and ordering the cancellation of its export quotas. These quotas were subsequently allocated to two newly-formed corporations, De Soleil Apparel Manufacturing Corporation and petitioner American Inter-Fashion Corporation (AIFC). The Office of the President later set aside this GTEB decision and remanded the case for new hearings, finding that Glorious Sun was denied due process. AIFC then filed this petition, arguing the GTEB decision was final and executory (res judicata) and alleging the Office of the President committed grave abuse of discretion in its review.

ISSUE

Whether the Supreme Court should refer the issues in this petition to the Sandiganbayan for disposition, given its exclusive jurisdiction over cases involving alleged ill-gotten wealth of the Marcos family and their associates.

RULING

No. The Court granted the motion for reconsideration and set aside its prior resolution referring the case to the Sandiganbayan. The Court clarified that while the Sandiganbayan has exclusive jurisdiction over the principal ill-gotten wealth cases and all incidents arising from them, the instant petition is not such an incident. This case is a separate administrative matter concerning the validity of the 1984 GTEB order cancelling Glorious Sun’s export quotas and the subsequent review by the Office of the President. The fact that the cancelled quotas were given to corporations later alleged to be crony entities does not transform this administrative proceeding into an incident of an ill-gotten wealth case. Glorious Sun itself was never sequestered, and AIFC’s sequestration had already been lifted.
The core issue—whether the Office of the President committed grave abuse of discretion in remanding the case for proper hearing—is a question properly within the Supreme Court’s certiorari jurisdiction under Rule 65, not within the Sandiganbayan’s jurisdiction to resolve. Upon review, the Court found no grave abuse of discretion, as the Office of the President correctly found a denial of due process in the GTEB proceedings. The petition was dismissed and the decision of the Office of the President was affirmed.