FACTS:

The Republic of the Philippines, represented by the PCGG, filed a complaint against Ferdinand Marcos and others. Palanca and other stockholders of BREDCO filed a motion to intervene, claiming legal interest in the properties subject to the complaint. They argued that the properties were registered in the name of BREDCO and that shares of stock were acquired under explained circumstances. The PCGG filed a motion to dismiss the intervention, asserting lack of jurisdiction and legal interest. The Sandiganbayan granted the intervention and admitted the answer in intervention. The PCGG petitioned for certiorari to annul the Sandiganbayan's resolution, arguing that the actions contravene national policy and are contrary to the law and jurisprudence. The petitioner claims that the jurisdiction of the Sandiganbayan has been settled in previous cases, which held that all cases related to illegally acquired or misappropriated assets of Marcos and cronies fall within the exclusive jurisdiction of the Sandiganbayan. The petitioner further argues that since intervention is ancillary and supplemental to the main case, the Sandiganbayan also has jurisdiction over it. Even though the case may be dismissed, the court decided to review the alleged errors of the Sandiganbayan due to public interest and policy considerations.

ISSUES:

1. Whether the Sandiganbayan has jurisdiction over the private respondents' action for intervention.

2. Whether the private respondents have a legal interest in the matter in litigation.

3. Whether the private respondents have the legal interest to intervene in the case.

4. Whether the State can be sued without its consent.

5. Whether or not the Republic of the Philippines is immune from suit and therefore should be dismissed as a party in the case.

6. Whether or not the private respondents' action for intervention in Civil Case No. 0025 is a suit or counter-suit against the Republic of the Philippines.

RULING:

1. The Sandiganbayan has jurisdiction over the private respondents' action for intervention since it has exclusive and original jurisdiction over the main civil case.

2. The private respondents have a legal interest in the matter in litigation as they have a 70% ownership of the capital stock of BREDCO, which was transferred to MCI, and are entitled to a share of 35% of the excess of all revenues over all disbursements.

3. The private respondents have the legal interest to intervene in the case. Under Section 2, Rule 12 of the Rules of Court, a person may intervene in a litigation if they show a legitimate and proper interest in the fund or property in question, especially if such interest cannot be otherwise protected. In this case, the private respondents have a legal interest in the success of the defendants, particularly in relation to the disputed assets of BREDCO. Therefore, their intervention should be granted.

4. The contention that the State cannot be sued without its consent is untenable. The filing of a complaint in intervention by the State in a case waives its right to non-suability. This principle was established in the case of Froilan v. Pan Oriental Shipping Co., where the Supreme Court held that the Government's filing of a complaint in intervention amounted to a waiver of its right to non-suability. Therefore, the State can be sued in this case through its intervention.

5. Yes, the Republic of the Philippines is immune from suit and should be dismissed as a party in the case. The claim against the Republic constitutes a charge against the government and cannot be entertained by the courts without the consent of the government.

6. No, the private respondents' action for intervention in Civil Case No. 0025 is not a suit or counter-suit against the Republic of the Philippines. The private respondents intervened in order to join the defendants in resisting the claims of the petitioner and did not ask for any affirmative relief against any party.

PRINCIPLES:

• Under the Rules of Court, a person may be permitted to intervene in an action if they have a legal interest in the matter in litigation or if they are so situated as to be adversely affected by a distribution or other disposition of property in the custody of the court or an officer thereof.

• Intervention is allowed to one who claims to be the owner or to have some interest in the property subject to litigation, without regard to the value of the property or the right claimed therein.

• A person may be admitted as an intervenor in a seques­tration suit involving title to personal property to have their claims to the possession of the property vindicated.

• In an action for possession of real or personal property, an intervenor may be admitted if they are an owner of the property to assist in the defense, claim the property for themselves, or obtain some other relief germane to the action.

• Intervention may be permitted when a person is so situated as to be adversely affected by a distribution or other disposition of property in the custody of the court or an officer thereof.

• Intervention pro interesse suo allows a person whose property is the subject of litigation between others to assert their property rights in court and have the property or its proceeds surrendered to them.

• A person who shows a legitimate and proper interest in the fund or property in question may be allowed to intervene in a litigation.

• The State can be sued through intervention if it waives its right to non-suability by filing a complaint in intervention.

• The Republic of the Philippines is immune from suit unless it consents to be sued.

• The action for intervention does not turn it into a suit or counter-suit against the party being intervened upon.