COJUANGCO vs SANDIGANBAYAN Case Digest

IMELDA O. COJUANGCO et al. v. SANDIGANBAYAN et al.

586 SCRA 790 (2009), EN BANC (Carpio Morales, J.)

While the general rule is that the portion of a decision that becomes the subject of execution
is that ordained or decreed in the dispositive part thereof, there are recognized exceptions to
this rule, one of which is where extensive and explicit discussion and settlement of the issue
is found in the body of the decision.

FACTS: The Republic of the Philippines (Republic) filed before the Sandiganbayan a "Complaint for
Reconveyance, Reversion, Accounting, Restitution and Damages," of the alleged ill-gotten wealth of
the Marcoses which have been invested in the Philippine Long Distance Telecommunication
Corporation (PLDT). Ramon and Imelda Cojuangco (Spouses Cojuangco) were subsequently
impleaded. The Sandiganbayan dismissed the complaint with respect to the recovery of the PLDT
shares. The Republic appealed to the Supreme Court, and the same issued a favorable ruling.

The Republic thereafter filed with the Sandiganbayan a Motion for the Issuance of a Writ of
Execution, praying for the cancellation of the shares of stock registered in the name of Prime
Holdings and the annotation of the change of ownership on PTICs Stock and Transfer Book. The
Republic further prayed for the issuance of an order for PTIC to account for all cash and stock
dividends declared by PLDT in favor of PTIC from 1986 up to the present including compounded
interests. The Sandiganbayan granted the same, except its prayer for accounting of dividends.

The Republic moved for reconsideration with respect to the denial of accounting of dividends, which
the Sandiganbayan granted. The Cojuangcos protested, alleging that the SCs decision did not
include in its dispositive portion the grant of dividends and interests accruing to the shares
adjudicated in favor of the Republic.

ISSUE: Whether or not the Republic is entitled to the dividends and interests accruing to the shares
despite its non-inclusion in the dispositive portion of the decision

HELD: The Cojuangcos insist on a literal reading of the dispositive portion of the SCs Decision,
excluding the dividends, interests, and earnings accruing to the shares of stock from being
accounted for and remitted.

The SC, in directing the reconveyance to the Republic of the 111,415 shares of PLDT stock owned
by PTIC in the name of Prime Holdings, declared the Republic as the owner of said shares and,
necessarily, the dividends and interests accruing thereto.

Ownership is a relation in law by virtue of which a thing pertaining to one person is completely
subjected to his will in everything not prohibited by law or the concurrence with the rights of another.
Its traditional elements or attributes include jus utendi or the right to receive from the thing that it
produces.

Contrary to the Cojuangcos contention, while the general rule is that the portion of a decision that
becomes the subject of execution is that ordained or decreed in the dispositive part thereof, there
are recognized exceptions to this rule, viz: (a) where there is ambiguity or uncertainty, the body of
the opinion may be referred to for purposes of construing the judgment, because the dispositive part
of a decision must find support from the decisions ratio decidendi; and (b) where extensive and
explicit discussion and settlement of the issue is found in the body of the decision.

In the Decision, although the inclusion of the dividends, interests, and earnings of the 111,415 PTIC
shares as belonging to the Republic was not mentioned in the dispositive portion of the Courts
Decision, it is clear from its body that what was being adjudicated in favor of the Republic was the
whole block of shares and the fruits thereof, said shares having been found to be part of the
Marcoses illgotten wealth, and therefore, public money.