G.R. No. L-77663. April 12, 1988.
PRESIDENTIAL COMMISSION ON GOOD GOVERNMENT, petitioner, vs. HON. EMMANUEL G. PEÑA, as Presiding Judge, RTC, NCJR, Br. CLII, Pasig, Metropolitan Manila, and YEUNG CHUN KAM, YEUNG CHUM HO and ARCHIE CHAN represented by YIM KAM SHING, respondents.

FACTS

The Presidential Commission on Good Government (PCGG) sequestered American Inter-fashion Corporation and De Soleil Apparel Manufacturing Corporation. The PCGG appointed an Officer-in-Charge (OIC) to manage the firms and designated authorized signatories for corporate bank accounts. On February 3, 1987, the OIC revoked the signatory authority of Yim Kam Shing, the representative of the minority Hongkong investors (private respondents), and designated new signatories. This revocation was approved by a PCGG Commissioner. Subsequently, the OIC withdrew funds to pay employee salaries.
Private respondents, through Yim Kam Shing, filed a damages suit with a prayer for a preliminary injunction in the Regional Trial Court (RTC) of Pasig against the bank, the PCGG, the Commissioner, and the OIC. They challenged the revocation of Yim Kam Shing’s signatory authority. The respondent RTC judge issued a temporary restraining order and later a writ of preliminary injunction, enjoining the enforcement of the PCGG’s revocation memorandum and restricting fund releases without Yim Kam Shing’s signature. The PCGG moved to dismiss, asserting the RTC’s lack of jurisdiction over the Commission and its acts.

ISSUE

Whether regional trial courts have jurisdiction to interfere with or restrain orders and actions of the Presidential Commission on Good Government concerning sequestered properties.

RULING

No. The Supreme Court granted the petition, annulling the RTC orders. The Court held that regional trial courts have no jurisdiction over the PCGG in the exercise of its powers under Executive Orders Nos. 1, 2, and 14, as amended, and Article XVIII, Section 26 of the 1987 Constitution . Jurisdiction over all cases involving the sequestration and recovery of ill-gotten wealth is vested exclusively and originally in the Sandiganbayan, subject to review only by the Supreme Court. The legal logic is grounded in the need for a unified, specialized, and expeditious recovery process free from interference by lower courts. Allowing RTCs to issue restraining orders against PCGG actions would lead to conflicting directives, hamper the Commission’s vital function, and cause dissipation of assets. The PCGG’s acts, such as managing sequestered corporations and designating signatories, are integral to its mandate to preserve assets pending final adjudication by the Sandiganbayan. Therefore, the respondent judge committed grave abuse of discretion by assuming jurisdiction and issuing injunctive relief against the PCGG. The Court made permanent its earlier temporary restraining order against the RTC proceedings.