Metrobank Vs Sandoval

(Metrobank v. Sandoval, G.R. No.
169677, February 18, 2013)

Facts:
On July 17, 1987, the Republic brought a complaint for reversion,

reconveyance, restitution, accounting and damages in the Sandiganbayan
against Andres V. Genito, Jr., Ferdinand E. Marcos, Imelda R. Marcos and
other defendants. The action was obviously to recover allegedly ill-gotten
wealth of the Marcoses, their nominees, dummies and agents.
Among the properties subject of the action were two parcels of commercial
land located in Tandang Sora (Old Balara), Quezon City, covered by
Transfer Certificate of Title (TCT) No. 266423 and TCT No. 266588 of the
Registry of Deeds of Quezon City registered in the names of Spouses
Andres V. Genito, Jr. and Ludivina L. Genito.
On February 5, 2001, the Republic moved for the amendment of the
complaint in order to implead Asian Bank (now Metrobank) as an additional
defendant.
Commenting on the motion, Asian Bank sought the deferment of any
action on the motion until it was first given the opportunity to test and assail
the testimonial and documentary evidence the Republic had already
presented against the original defendants, and contended that it would be
deprived of its day in court if a separate trial were to be held against it
without having been sufficiently apprised about the evidence the Republic
had adduced before it was brought in as an additional defendant.
In its reply to Asian Bank's comment, the Republic maintained that a
separate trial for Asian Bank was proper because its cause of action
against Asian Bank was entirely distinct and independent from its cause of
action against the original defendants; and that the issue with respect to
Asian Bank was whether Asian Bank had actual or constructive knowledge
at the time of the issuance of the TCTs for the properties in its name that
such properties were the subject of the complaint in Civil Case No. 0004,
while the issue as to the original defendants was whether they had
"committed the acts complained of as constituting illegal or unlawful
accumulation of wealth which would, as a consequence, justify forfeiture of
the said properties or the satisfaction from said properties of the judgement
that may be rendered in favor of the Republic.
Sandiganbayan granted motion for separate trial and denied MR of
Metrobank. Hence, this petition for certiorari.
Issue:
WON Sandiganbayan committed GADALEJ?
WON the Republic is entitled to a separate Trial against Asia Bank?
Held:
The Sandiganbayan gravely abused its discretion in granting the Republic's motion
for separate trial, but was correct in upholding its jurisdiction over the Republic's
claim against Asian Bank.
The rule on separate trials in civil actions is found in Section 2, Rule 31 of the Rules
of Court, which reads:
Section 2.Separate trials. The court, in furtherance of convenience or to avoid
prejudice, may order a separate trial of any claim, cross-claim, counterclaim, or
third-party complaint, or of any separate issue or of any number of claims, crossclaims, counterclaims, third-party complaints or issues.
The text of the rule grants to the trial court the discretion to determine if a separate
trial of any claim, cross-claim, counterclaim, or third-party complaint, or of any
separate issue or of any number of claims, cross-claims, counterclaims, third-party
complaints or issues should be held, provided that the exercise of such discretion is
in furtherance of convenience or to avoid prejudice to any party.
We conclude that the Sandiganbayan committed grave abuse of its discretion in
ordering a separate trial as to Asian Bank (Metrobank) on the ground that the issue
against Asian Bank was distinct and separate from that against the original
defendants. Thereby, the Sandiganbayan veered away from the general rule of
having all the issues in every case tried at one time, unreasonably shunting aside
the dictum in Corrigan, supra, that a "single trial will generally lessen the delay,
expense, and inconvenience to the parties and the courts."
Exceptions to the general rule are permitted only when there are extraordinary
grounds for conducting separate trials on different issues raised in the same case,
or when separate trials of the issues will avoid prejudice, or when separate trials of
the issues will further convenience, or when separate trials of the issues will
promote justice, or when separate trials of the issues will give a fair trial to all
parties. Otherwise, the general rule must apply.
As we see it, however, the justification of the Sandiganbayan for allowing the
separate trial did not constitute a special or compelling reason like any of the
exceptions. To begin with, the issue relevant to Asian Bank was not complicated. In
that context, the separate trial would not be in furtherance of convenience. And,
secondly, the cause of action against Asian Bank was necessarily connected with
the cause of action against the original defendants. Should the Sandiganbayan
resolve the issue against Spouses Genito in a separate trial on the basis of the
evidence adduced against the original defendants, the properties would be thereby
adjudged as ill-gotten and liable to forfeiture in favor of the Republic
without Metrobank being given the opportunity to rebut or explain its side. The
outcome would surely be prejudicial towards Metrobank.
Consequently, the Sandiganbayan has original exclusive jurisdiction over the claim
against Asian Bank, for the Court has ruled in Presidential Commission on Good
Government v. Sandiganbayan, that "the Sandiganbayan has original and exclusive
jurisdiction not only over principal causes of action involving recovery of ill-gotten
wealth, but also over all incidents arising from, incidental to, or related to such
cases."

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(Metrobank v. Sandoval, G.R. No.

169677, February 18, 2013)

On July 17, 1987, the Republic brought a complaint for reversion,

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