SANDIGANBAYAN G.R. No. 103068 l June 22, 2001 En Banc l Justice Ynares-Santiago Digest by Karen Joy R. Masapol
Facts:
Meat Packaging Corporation, a corporation wholly
owned by the Government Service Insurance System, entered into a Lease Agreement with the Philippine Integrated Meat Corporation for 3 parcels of land including a meat processing and packaging plant in Pasig City.
However, the properties of PIMECO including the meat
processing and packaging plant, were sequestered by the Philippine Commission on Good Government.
GSIS asked for the exclusion of the meat packaging
plant from the sequestered assets of PIMECO, inasmuch as the same is owned by MPCP. MPCP also sought for the turnover of the plant since the lease- purchase agreement was rescinded due to nonpayment of rental by PIMECO.
PCGG granted the turn-over to GSIS of the meat
processing and packaging plant.
Meanwhile, PCGG instituted with the Sandiganbayam
Civil Case No. 0024 “Republic v. Sabido” where Sabido assailed the validity of the turn-over of PIMECO to GSIS.
The Sandiganbayan issued a Resolution declaring the
turn-over of the meat packing complex as null and void ab initio and upheld the tender of payment by PCGG.
ISSUE:
Did Sandiganbayan have jurisdiction over Meat
Packing Corporation of the Philippines?
RULING: YES
Jurisdiction over the person of the defendant in civil
cases is acquired either by his voluntary appearance in court and his submission to its authority or by service of summons.
Furthermore, the active participation of a party in the
proceedings is tantamount to an invocation of the court’s jurisdiction and a willingness to abide by the resolution of the case, and will bar said party from later on impugning the court or body’s jurisdiction.
In this case, MPCP is precluded from questioning the
jurisdiction of the Sandiganbayan over its person in Civil Case No. 0024, considering that, as shown by the records, it actively participated in the discussion of the merits of the said case, even going to the extent of seeking affirmative relief.