Meat Packing Corporation of the Philippines v. The Honorable Sandiganbayan

Summary

This case involved a dispute over a lease-purchase agreement for a meat packing plant between MPCP (owned by GSIS) and PIMECO. After PCGG sequestered PIMECO's assets in 1986, including the lease agreement, MPCP attempted to rescind the contract for non-payment of rentals. PCGG later tendered P5 million as partial payment of rental arrears, which MPCP refused, claiming the agreement was already rescinded. The Sandiganbayan ordered MPCP to accept the payment, finding valid consignation under Civil Code Article 1256. The Supreme Court affirmed, ruling that MPCP's refusal was unjustified since it had accepted payments after the alleged rescission date, and that MPCP voluntarily submitted to the Sandiganbayan's jurisdiction through active participation in the proceedings. The decision clarifies the requirements for valid consignation and voluntary submission to jurisdiction in commercial lease disputes involving sequestered assets.