Mid-Pasig Land Development Corporation vs. Sandiganbayan

The Supreme Court granted the petition for certiorari and set aside the Sandiganbayan's default order after private respondent confessed judgment and withdrew his objections, rendering the resolution of the procedural and substantive merits unnecessary.

The case arises from the sequestration of assets allegedly held by nominees of former President Ferdinand Marcos following the 1986 EDSA Revolution. Jose Y. Campos, claiming to hold shares as a Marcos nominee, turned over control of Mid-Pasig Land Development Corporation and Anchor Estate Corporation—along with titles to valuable properties in Ortigas Center—to the PCGG. Ricardo Silverio, asserting beneficial ownership of 30% of Anchor Estate Corporation, challenged the transfer of titles to Mid-Pasig as fraudulent and sought reconveyance of the properties, precipitating procedural disputes regarding default and jurisdiction before the Sandiganbayan.

• Anchor Estate Corporation allegedly purchased a 16-hectare parcel of land from Ortigas and Company Limited Partnership on May 31, 1968 for P6,400,000.00.
• On August 10, 1971, title to the property was transferred in favor of Mid-Pasig Land Development Corporation instead of Anchor Estate Corporation.
• Through a Deed of Transfer dated December 9, 1974, an additional 2.4 hectares was sold by Ortigas to Mid-Pasig.
• Transfer Certificate of Title Nos. 337158 (for the 16-hectare lot) and 469702 were issued in the name of Mid-Pasig.
• After the February 1986 revolution, Jose Y. Campos, then president and majority stockholder of both Anchor and Mid-Pasig, turned over control of both corporations and the two certificates of title to the Presidential Commission on Good Government (PCGG).
• Campos claimed that he and other shareholders controlling 70% of Anchor were acting and holding said shares as nominees of former President Ferdinand E. Marcos.
• Ricardo C. Silverio claimed to be the "actual beneficial and legal owner" of the remaining 30% of Anchor Estate Corporation.
• Silverio alleged he was prejudiced by the "fraudulent" cession of the two parcels of land totaling 18.2 hectares, now valued in billions of pesos and situated within the Ortigas Center in Pasig City.

• PCGG argued that it was not duty bound to file an answer to the amended complaint pending resolution of Silverio's motion to declare Mid-Pasig in default dated December 14, 1992.
• PCGG alternatively argued that assuming it was duty bound to file an answer, its failure to file said answer was due to mistake regarding a difficult question of law or procedure.
• In its Post Hearing Memorandum dated September 9, 1996, petitioner contended that the Sandiganbayan has no jurisdiction to hear and decide Civil Case No. 0147 because the complaint does not involve the recovery of supposed ill-gotten wealth, as the property had already been ceded to the government by Jose Y. Campos.

• Initially, Silverio sought to declare Mid-Pasig in default for failure to file an answer to the complaint and amended complaint.
• In his Manifestation and Confession of Judgment dated August 29, 1996, Silverio withdrew his objections to the Petition and his efforts to declare Mid-Pasig in default after considering that: (a) counsel for Mid-Pasig manifested that the answer to the amended complaint would be the same as the answer filed for co-defendant PCGG; (b) said answer by PCGG would inure to the benefit of Mid-Pasig even if barred from filing its own answer, since Mid-Pasig and PCGG appear to represent the same interest; and (c) to avoid further delay in the case.
• Silverio allowed the prayer for relief in the Petition to be granted without further delay.

• Procedural Issues:
  • Whether the Sandiganbayan gravely abused its discretion in declaring Mid-Pasig in default despite the pending motion to declare it in default and the excusable nature of the failure to file answer.
  • Whether the filing of a Manifestation and Confession of Judgment by private respondent rendered the petition moot.
• Substantive Issues:
  • Whether the Sandiganbayan has jurisdiction over the complaint for reconveyance considering that the property has already been ceded to the government and does not involve recovery of ill-gotten wealth.
  • Whether Ricardo C. Silverio is the real party in interest in the suit.

• Procedural:
  • The Supreme Court granted the petition for certiorari and set aside the Sandiganbayan's resolutions declaring Mid-Pasig in default in Civil Case No. 0147.
  • The Court ruled that with the filing of the Manifestation and Confession of Judgment by private respondent, there was no longer any necessity to pass upon the merits of the procedural issues raised.
  • The Court simply granted the motion and thus granted the petition, giving PCGG fifteen days from receipt to file its answer to the Amended Complaint.
• Substantive:
  • The Court did not rule on the substantive issues regarding the Sandiganbayan's jurisdiction over the reconveyance complaint and Silverio's standing as real party in interest because these became moot after the private respondent confessed judgment and withdrew his objections.

• Confession of Judgment — A procedural device where a party manifests in writing that he withdraws his objections to a petition and allows the prayer for relief to be granted, effectively rendering the resolution of the merits unnecessary and warranting the grant of the petition without further proceedings.
• Excusable Delay/Default — Failure to file an answer may be excused when due to mistake regarding a difficult question of law or procedure, although this was not explicitly ruled upon by the Court given the confession of judgment.

• "With the filing of the above 'Manifestation and Confession of Judgment' by private respondent, there is no longer any necessity for this Court to pass upon the merits of the case. We simply grant the said motion and thus grant the petition."
• "WHEREFORE, the petition is hereby GRANTED. The assailed Resolutions of the Sandiganbayan declaring petitioner in default in Civil Case No. 0147 are SET ASIDE."