REPUBLIC OF THE PHILIPPINES (Presidential Commission on Good Government [PCGG]), vs. SANDIGANBAYAN, JOSE L. AFRICA, MANUEL H. NIETO, JR., FERDINAND E. MARCOS, IMELDA R. MARCOS, FERDINAND R. MARCOS, JR., ROBERTO S. BENEDICTO, JUAN PONCE ENRILE, and POTENCIANO ILUSORIO.
- G.R. Number: G.R. No. 108292
- Promulgated: 1993-09-10
- Ponente: Melo, J.
Doctrine
Although the State is generally immune from estoppel for acts or mistakes of its officials, that principle does not justify endless disturbance of a contract freely and in good faith executed between parties.
Where third persons have an available separate proceeding before the Sandiganbayan, intervention under Section 2(b), Rule 12 may be proscribed; courts should consider delay, prejudice, and adequacy of protection of intervenor's rights in exercising discretion under Sec. 2(b).
Facts
This is an EN BANC decision of the Supreme Court in G.R. No. 108292 dated 10 September 1993.
The Court agreed with observations of the Sandiganbayan regarding the case before it.
The Court held that the plaintiff is estopped from questioning the validity of the Compromise Agreement because it had already received benefits thereunder.
The Court noted that, while the State is generally immune from estoppel for acts or mistakes of its officials, this does not permit indefinite disturbance of a contract freely and in good faith executed between parties.
The Court pointed out that third persons have an available separate proceeding before the Sandiganbayan and that intervention under Section 2(b), Rule 12, may be proscribed; it quoted Sec. 2(b) and ultimately dismissed the petitions and lifted the restraining orders.
Issues
Whether the plaintiff may question the validity of the Compromise Agreement despite having received benefits under it.
Whether intervention under Section 2(b), Rule 12 of the Revised Rules of Court is proper where third persons have an available separate proceeding before the Sandiganbayan.
Ruling
The Court held that the plaintiff is estopped from questioning the validity of the Compromise Agreement because it received benefits thereunder.
The Court ruled that the availability of a separate proceeding for third persons before the Sandiganbayan proscribes intervention under Section 2(b), Rule 12.
The petitions in the listed G.R. numbers were dismissed; the restraining orders dated March 10, March 23, and 24 March 1993 were lifted, and the parties to the compromise agreement were ordered to comply strictly with its terms.
Keywords
G.R. No. 108292, compromise agreement, Presidential Commission on Good Government (PCGG), Sandiganbayan, Civil Cases No. 0024 and No. 0028, reconveyance, reversion, accounting, restitution, damages, global settlements, plea bargaining agreement, Settlement and Partial Release of Claims, sequestrations, absolute immunity, criminal investigation or prosecution, Act No. 3019, grave abuse of discretion, contrary to law, morals, good customs, public policy, and public order, estoppel