Case Details
Case Title: Cojuangco, Jr. vs. Republic
Case Name (Short Form): Cojuangco vs. Republic
Case No.: G.R. No. 180705
Volume No. (SCRA): 686 SCRA 472
Petitioner: Eduardo M. Cojuangco, Jr.
Respondent: Republic of the Philippines
Decision Date: November 27, 2012
Ponente: Justice Presbitero J. Velasco, Jr.
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Facts
The PCGG, representing the Republic, filed Civil Case No. 0033-A before the Sandiganbayan,
alleging that Eduardo Cojuangco, Jr., as a Marcos crony, unlawfully acquired controlling shares
in United Coconut Planters Bank (UCPB) using coconut levy funds via the PCA-Cojuangco
Agreement.
The Sandiganbayan, through Partial Summary Judgment (PSJ-A, 2003), declared the
agreement void for lack of publication and lack of valuable consideration, and held the shares
as belonging to the Republic.
Cojuangco questioned this before the Supreme Court, claiming lack of jurisdiction of the
Sandiganbayan and improper summary judgment.
IRRDD Format
ISSUE 1
Does the Sandiganbayan have jurisdiction over the recovery case involving alleged ill-gotten
wealth (UCPB shares)?
RULING:
Yes. The Sandiganbayan has exclusive original jurisdiction.
RATIO:
Jurisdiction depends on the allegations in the complaint, not defenses.
The PCGG alleged acquisition of ill-gotten wealth by a Marcos crony.
Under E.O. No. 14, Sec. 2, Sandiganbayan has exclusive jurisdiction over all ill-gotten
wealth cases, civil or criminal.
DOCTRINE:
When a complaint alleges ill-gotten wealth, jurisdiction lies exclusively with the
Sandiganbayan.
ISSUE 2
Was the Sandiganbayan correct in rendering Partial Summary Judgment declaring the PCA–
Cojuangco Agreement void?
RULING:
Yes. The issuance of Partial Summary Judgment was proper.
RATIO:
Summary judgment is proper when no genuine issue of material fact exists.
Issues raised (lack of publication; lack of consideration) were purely legal, not factual.
The presumption of valid consideration (Rule 131, Sec. 3, Rules of Court) was rebutted
by the Republic.
DOCTRINE:
Summary judgment is proper when only legal issues remain and no factual disputes exist.
FALLO / DISPOSITION
Petition DENIED.
Sandiganbayan’s Partial Summary Judgment AFFIRMED.
Disputed UCPB shares declared owned by the Republic.
Definitions / Glossary
PCGG (Presidential Commission on Good Government): Body created by E.O. No. 1
(1986) to recover ill-gotten wealth of Marcos, his family, and cronies.
Sandiganbayan: Special graft court with jurisdiction over cases involving public
officials and ill-gotten wealth (Constitution, Art. XI).
Partial Summary Judgment (PSJ-A): Judgment resolving certain issues when no
factual dispute exists (Rule 35, Rules of Court).
Ill-gotten wealth: Assets unlawfully acquired through misuse of public funds or position.
Coconut levy funds: Compulsory collections from coconut farmers, treated as public
funds.
PCA (Philippine Coconut Authority): Government agency overseeing coconut
industry.
UCPB (United Coconut Planters Bank): Bank whose controlling shares were subject of
litigation.
Valuable consideration: Requisite for contracts under Civil Code, Art. 1350–1354.
Void ab initio: “Void from the beginning” — contract without legal effect from
inception.
E.O. No. 14, Sec. 2: Grants Sandiganbayan exclusive jurisdiction over ill-gotten wealth
cases.
Rule 131, Sec. 3, Rules of Court: Lists disputable presumptions, including sufficient
consideration.
