Republic of the Philippines v.

Sandiganbayan
GR 104768, 21 July 2003, En Banc, Carpio J.
CASE #1 Republic of the Philippines v. Sandiganbayan, Major General Josephus Q. Ramas and
Elizabeth Dimaano
PROVISION Article III Section 2
“ The right of the people to be secure in their persons, houses, papers, and effects
against unreasonable searches and seizures of whatever nature and for any purpose
shall be inviolable, and no search warrant or warrant of arrest shall issue except upon
probable cause to be determined personally by the judge after examination under
oath or affirmation of the complainant and the witnesses he may produce, and
particularly describing the place to be searched and the persons or things to be
seized.”
FACTS - The AFP Board investigates Major General Josephus Q. Ramas of reports of
alleged unexplained wealth founded in the house of Elizabeth Dimaano the
alleged mistress and former secretary of Ramas pursuant to PCGG and its AFP
Board.
- The confiscated items include military equipment/items and communications
equipment, money amounting to P2,870,000.00 and $50,000 US Dollars.
- After scrutiny of the SALN, it was found out that even if Dimaano were to claim
that the money was hers, she had no visible source of income to produce the
amount of the money.
- It was disclosed that the respondent has an unexplained wealth of
P104,134.60.
- The Sandiganbayan dismissed the amended complaint based on:
Non-compliance with Supreme Court rulings in similar cases.
Lack of a preliminary inquiry against Ramas and Dimaano.
Insufficient evidence to establish a prima facie case.
Illegal search and seizure of the items in question.
-
ISSUE 1. Whether or not the PCGG has jurisdiction to investigate private respondents.
2. Whether the Sandiganbayan erred in dismissing the case before completion of
the presentation of petitioner’s evidence.
3. Whether the Sandiganbayan erred in declaring the properties confiscated
from Dimaano’s house as illegally seized and inadmissible as evidence.
HELD/RULING 1. PCGG has no jurisdiction. Pursuant to EO No. 1 under Section 2 the PCGG
shall be charged with the task of assisting the President regarding the
following matters:

“ The recovery of ill-gotten wealth accumulated by former President Ferdinand E.

Petitioner argues that Ramas was a subordinate of a Pres. Ferdinand Marcos but the
Supreme Court ruled that a mere position in the military does not automatically make
him a “subordinate”.

It does not suffice as in this case; the respondent is or was a government official or
employee during the administration of former president Marcos. There must be a
prima facie showing that Ramas unlawfully accumulated wealth by virtue of his close
association or relation with former Pres. Marcos and or his wife.

2. No. Base on the circumstances the petitioner has only itself to blame for
the failure to complete the presentation of its evidence. First the case has
been pending for four years before the Sandiganbayan dismissed it.

3. No. First Dimaano was not present during the raid only her. Second the
raiding team seized the items detailed in the seizure receipt together
with other items not included in the search warrant.
DOCTRINE
 Philippine Blooming Mills Employment Organization v. Philippine Blooming Mills Co. Inc
GR L-31195, 5 June 1973, En Banc, Makasiar J.
CASE #2 Philippine Blooming Mills Employment Organization, Nicanor Tolentino, Florencio,
Padrigano Rufino, Roxas Mariano De Leon, Asencion Paciente, Bonifacio Vacuna,
Benjamin Pagcu and Rodulfo Munsod, Petitioners,
Vs. Philippine Blooming Mills Co., Inc. And Court of Industrial Relations,
PROVISION
FACTS - The Philippine Blooming Mills Employees Organization (PBMEO), a legitimate
labor union, planned a mass demonstration on March 4, 1969, to protest
alleged abuses by the Pasig police. The demonstration was to involve workers
from the first, second, and third shifts, with prior notice given to the
Philippine Blooming Mills Co., Inc. (respondent company). In response, the
company warned that workers participating without prior leave would face
dismissal, citing a violation of the collective bargaining agreement (CBA),
particularly the "No Strike, No Lockout" clause.
- Despite the company’s warnings, the petitioners proceeded with the
demonstration, leading the company to charge them with violating Republic
Act No. 875 and the CBA. The petitioners argued that the demonstration was a
lawful exercise of their constitutional right to free speech and not a strike
against the company.
- After reviewing the case, Judge Joaquin M. Salvador concluded on September
15, 1969, that PBMEO had engaged in bad faith bargaining and, as a result, the
petitioners were found guilty of unfair labor practices and lost their status as
employees of the respondent company.
ISSUE Whether the respondents’ act of concluding that the petitioners acted in bad faith for
proceeding with the demonstration and expelling them from the company is
unconstitutional.
HELD/RULING The court ruled in favor of the employees, ordering the annulment of previous
decisions and directing the company to reinstate the dismissed employees with back
pay, less one day’s pay and any earnings from other sources during their separation.

The employer's claim that it would suffer damage from the absence of employees is
seen as an attempt to protect property rights, but human rights, particularly freedom
of expression, assembly, and petition, take precedence over property rights. The
employees were protesting alleged abuses by local police, which directly impacted
their lives and families. The employer's refusal to allow employees to participate in
the demonstration and subsequent dismissals were seen as a violation of
constitutional rights and an unfair labor practice.

The company was found guilty of unfair labor practices for preventing the employees
from exercising their rights to free speech, assembly, and petition. The refusal to allow
the workers to join the protest led to their wrongful dismissal, which also violated
social justice principles enshrined in the Constitution. The court condemned the
company's actions as opportunistic and self-serving, emphasizing that employees'
fundamental rights must be protected.
DOCTRINE