Chavez vs. PCGG

Intervention under Section 2, Rule 19 of the Rules of Court must be filed before the rendition of judgment; it cannot be allowed after a decision has become final and executory, particularly where the movants are merely incidental parties whose contractual claims cannot validate agreements that are null and void for violating the Constitution and the laws.

The case arose from the General and Supplemental Agreements dated December 28, 1993, entered into between the Presidential Commission on Good Government (PCGG) and the Marcos family concerning the disposition of sequestered properties and ill-gotten wealth accumulated during the Marcos regime. These agreements were challenged by petitioner Francisco I. Chavez through a petition for mandamus directly filed with the Supreme Court, alleging that they violated constitutional provisions on public disclosure and were contrary to law.

• On December 28, 1993, the PCGG entered into General and Supplemental Agreements with the Marcos family concerning the disposition of sequestered properties and the settlement of ill-gotten wealth cases pending before the Sandiganbayan (Civil Case No. 141).
• Petitioner Francisco I. Chavez filed a petition for mandamus on October 3, 1997, directly with the Supreme Court, seeking to enforce the constitutional right to information and assailing the Agreements as unconstitutional and contrary to law.
• The Supreme Court, on December 9, 1998, declared the Agreements "NULL AND VOID for being contrary to law and the Constitution."
• Ma. Imelda Marcos-Manotoc, Ferdinand R. Marcos II, and Irene Marcos-Araneta (the Marcos children) alleged they were parties and signatories to the Agreements (except Ferdinand R. Marcos II who did not sign but adhered by filing the motion).
• The Marcos children filed their Motion for Leave to Intervene and Partial Motion for Reconsideration on January 22, 1999, after the Decision had become final and the period for reconsideration had lapsed for the original parties.
• The movants claimed that the PCGG granted their mother, Imelda Marcos, access rights to one of the sequestered properties, which they argued constituted partial implementation and implied ratification of the Agreements.
• The original petition was well-publicized, and the Marcos children had long been active in Philippine political and social life, with no plausible excuse for their failure to intervene earlier.

• Chavez argued that the original petition filed on October 3, 1997, was well-publicized, as were its proceedings including the oral arguments held on March 16, 1998.
• He asserted that the movants have long been back in the mainstream of Philippine political and social life and could not feign unawareness of the petition prior to its disposition.
• He maintained that the assailed Decision had become final and executory, as the original parties had not filed any motion for reconsideration and the period for doing so had long lapsed.
• He contended that the movants were merely incidental, not indispensable, parties to the case, and that their exclusion did not violate due process.

• The Marcos children (movants) claimed they were parties and signatories to the General and Supplemental Agreements and therefore had a legal interest in the matter warranting intervention.
• They argued that their exclusion from the proceedings resulted in a denial of their constitutional rights to due process and equal protection of the laws.
• They invoked the "principle of hierarchical administration of justice," alleging that the Supreme Court preempted the Sandiganbayan by ruling on the validity of the Agreements despite pending proceedings in the latter court.
• They insisted that there was nothing "secret" about the agreements since they were filed with the Sandiganbayan, rendering the petition for disclosure moot.
• They claimed that the PCGG's grant of access rights to their mother constituted partial implementation equivalent to implied ratification of the Agreements.

• Procedural:
  • Whether a motion to intervene may be granted after the rendition of final judgment under Section 2, Rule 19 of the Rules of Court.
  • Whether the Marcos children are indispensable parties whose exclusion violates due process.
  • Whether the filing of the petition directly with the Supreme Court violates the principle of hierarchical administration of justice.
• Substantive Issues:
  • Whether the exclusion of the Marcos children from the proceedings constitutes a denial of due process and equal protection.
  • Whether void agreements may be ratified or validated by partial implementation or the passage of time.
  • Whether the petition presents an actual case and judicial question ripe for adjudication.

• Procedural:
  • Intervention is not allowed after final judgment; Section 2, Rule 19 explicitly requires that a motion to intervene be filed "before rendition of judgment," and the movants filed their motion on January 22, 1999, well after the December 9, 1998 Decision.
  • The Marcos children are merely incidental parties, not indispensable parties, because the validity of the agreements depends on constitutional and legal standards independent of their contractual claims; the case primarily assailed the PCGG's exercise of discretion, not the contractual rights of the Marcos children.
  • The principle of hierarchical administration of justice applies to cases involving factual questions requiring reception of evidence; the Supreme Court may exercise primary jurisdiction over cases involving purely constitutional and legal questions of public interest, as the Court is not a trier of facts.
  • The Court may at its sound discretion suspend procedural rules in the interest of substantial justice.
• Substantive:
  • No denial of due process occurred because the movants have no legal interest to protect in a proceeding seeking to nullify void contracts; the voidness of the agreements affects all contractors equally, and no argument by the contractors can validate illegal and unconstitutional stipulations.
  • Void contracts are inexistent and produce no legal effects; they cannot be ratified or validated by partial performance or passage of time (Article 1409, Civil Code); the defense of inexistence or absolute nullity is imprescriptible.
  • The petition presents an actual case and judicial question; mandamus lies to enforce constitutional rights, and the PCGG committed grave abuse of discretion by entering into agreements violating the Constitution, which the Court is duty-bound to strike down.

• Intervention After Final Judgment — Under Section 2, Rule 19 of the Rules of Court, a motion to intervene must be filed before rendition of judgment; intervention cannot be permitted once a decision has become final and executory, and no valid excuse exists for late filing when the case was well-publicized.
• Indispensable vs. Incidental Parties — Indispensable parties are those whose interest will be directly affected by the judgment, while incidental parties may be affected only collaterally; exclusion of incidental parties does not violate due process where the case involves the validity of public acts independent of private contractual claims.
• Void Contracts (Inexistent Contracts) — Contracts that violate the Constitution and laws are null and void ab initio, vest no rights, create no obligations, produce no legal effects, are not susceptible of ratification, and cannot be invoked by persons whose interests are not directly affected (Article 1409, Civil Code).
• Hierarchy of Courts — The principle generally applies to cases involving factual questions requiring reception of evidence; the Supreme Court may exercise primary jurisdiction over cases involving purely constitutional and legal questions of transcendental importance to avoid unnecessary delays.
• Mandamus to Enforce Constitutional Rights — Mandamus is a proper recourse to compel the performance of a public duty mandated by the Constitution, and the Supreme Court has original jurisdiction over such petitions when grave abuse of discretion is alleged.

• "Intervention can no longer be allowed in a case already terminated by final judgment."
• "A contract that violates the Constitution and the law is null and void ab initio and vests no rights and creates no obligations. It produces no legal effect at all."
• "The Supreme Court is not a trier of facts."
• "Void or inexistent contracts... are not susceptible of ratification... The action or defense for the declaration of their inexistence or absolute nullity is imprescriptible."

• Rabino v. Cruz, 222 SCRA 493 (1993) — Cited for the rule that intervention must be filed before rendition of judgment.
• Lorenzana v. Cayetano, 78 SCRA 485 (1977) — Cited for the rule on timing of intervention.
• Development Bank of the Philippines v. Court of Appeals, 116 SCRA 636 (1982) — Cited for the doctrine on void contracts.
• Yuchengco, Inc. v. Velayo, 115 SCRA 307 (1982) — Cited for the principle that void contracts produce no legal effects.
• Tongoy v. Court of Appeals, 123 SCRA 99 (1983) — Cited for the characteristics of void or inexistent contracts, particularly that they are not susceptible of ratification and the defense of nullity is imprescriptible.
• Santiago v. Vasquez, 217 SCRA 633 (1993) — Cited for the principle of hierarchy of courts.
• Gordon v. Executive Secretary, GR No. 134071 (1998) — Cited for the principle of hierarchy of courts.
• Ramos v. Court of Appeals, 269 SCRA 34 (1997) — Cited for the rule that procedural rules may be suspended in the interest of substantial justice.
• Guingona Jr. v. Gonzales, 214 SCRA 789 (1992) — Cited for the definition of grave abuse of discretion.

• Section 2, Rule 19, Rules of Court — Governs the timing of motions to intervene, requiring they be filed before rendition of judgment.
• Article 1409, Civil Code — Enumerates void and inexistent contracts and their characteristics, including that they are not susceptible of ratification.
• Constitutional Provisions on Right to Information — Referenced as the basis for the original petition seeking disclosure of public transactions and enforcement of transparency in government dealings.

• N/A (Chief Justice Davide, Jr., and Justices Melo, Vitug, and Quisumbing concurred in the Resolution without writing separate opinions.)