Republic of the Philippines v. Tacloban City Ice Plant

G.R. No. 106413 (July 5, 1996)

Tacloban City Ice Plant claims Price Mansion ownership; UBC disputes it post-sale. Supreme Court mandates hearing.

Facts:

On March 18, 1986, the Presidential Commission on Good Government (PCGG) placed under sequestration the Price Mansion, a property in Tacloban City, believing it to be owned by Benjamin "Kokoy" Romualdez. The Tacloban City Ice Plant, Inc. (TCIP), a family corporation, claimed ownership of the Price Mansion, asserting that it had been sold to them by the heirs of the original owners, Walter Scott Price and Simeona K. Price, through a Deed of Extrajudicial Partition and Sale dated March 1978.

The PCGG conducted hearings where TCIP's representatives, including Engineer Wilson Chan and Professor Esteban A. Ocampo from the National Historical Commission, testified in support of TCIP's claim. The PCGG ultimately concluded that TCIP had sufficiently substantiated its ownership claim and lifted the sequestration order on February 27, 1987, stating that the Price Mansion did not constitute ill-gotten wealth.

Despite this order, the PCGG retained possession of the Price Mansion and included it as an asset in a case against Romualdez. TCIP requested the PCGG to withdraw the property from the list of assets, which was partially complied with, but the property remained in the PCGG's possession. On June 28, 1989, the Sandiganbayan ordered the turnover of the Price Mansion to TCIP, but the PCGG failed to comply.

In February 1990, TCIP sold the Price Mansion to Allied Banking Corporation, acting as trustee for the College Assurance Plan Philippines, Inc. (CAPP). TCIP was to remove an antenna/tower installed by PRTV-12, another sequestered entity, and transfer possession to Allied. TCIP later filed a motion with the Sandiganbayan to compel the PCGG to turn over the property, which led to the Sandiganbayan's resolutions on October 1, 1991, and July 23, 1992, declaring the previous order final and denying the motion for reconsideration.

Legal Issues:

  1. Whether the Sandiganbayan's resolution declaring the Price Mansion as belonging to TCIP was final and executory.
  2. Whether the lifting of the sequestration order rendered the Price Mansion free from claims of being ill-gotten property.
  3. The implications of the intervention by Universal Broadcasting Corporation (UBC) claiming ownership of the Price Mansion.

Arguments:

  • Petitioner (Republic of the Philippines):

    • Argued that the Sandiganbayan's resolution was interlocutory and could not be final.
    • Contended that the lifting of the sequestration did not necessarily mean the property was not ill-gotten, as it could still be linked to Romualdez through UBC.
    • Asserted that the Sandiganbayan ignored critical allegations in the amended complaint regarding the ownership of the Price Mansion.

  • Respondents (TCIP and Allied Banking Corporation):

    • Maintained that the Sandiganbayan's resolution was final and that TCIP had established its ownership of the Price Mansion.
    • Argued that the PCGG's failure to turn over the property constituted an impairment of TCIP's ownership rights.
    • Contended that the intervention by UBC should not affect the finality of the Sandiganbayan's resolution.

Court's Decision and Legal Reasoning:

The Supreme Court ruled that the Sandiganbayan's resolution of June 28, 1989, was indeed final and had definitively determined that the Price Mansion did not belong to Benjamin "Kokoy" Romualdez. The Court emphasized that the lifting of the sequestration order meant that the property lost its character as ill-gotten wealth, and the Sandiganbayan lost jurisdiction over it once the property was ordered to be turned over to TCIP.

The Court also noted that the issue of UBC's claim to ownership had not been resolved in the previous proceedings. It ordered the Sandiganbayan to conduct a hearing to determine UBC's claim and the Republic's right to retain possession of the property. The resolutions of October 1, 1991, and July 23, 1992, were suspended pending this determination.

Significant Legal Principles Established:

  1. A resolution lifting a sequestration order can be considered final if it definitively resolves the ownership issue of the property in question.
  2. The lifting of sequestration does not automatically cleanse a property of claims of being ill-gotten; such claims must be adjudicated.
  3. The right to intervene in a case may still be valid even after a resolution has been made, particularly if new claims arise that were not previously adjudicated.