Vicente B. Chuidian v. Sandiganbayan (Fifth Division)

Summary

This case involves the government's effort to recover alleged ill-gotten wealth from Vicente Chuidian, purported dummy of the Marcoses. The dispute centered on a US$4.6 million Letter of Credit issued by PNB to Chuidian as part of a 1985 compromise agreement with PHILGUARANTEE. After the PCGG sequestered the L/C in 1986, the government obtained a writ of attachment over it in 1993. Chuidian challenged the attachment four years later, citing his return to the Philippines, favorable foreign judgments, and government laches. The Supreme Court dismissed his petition, ruling that supervening events do not constitute grounds for discharge under Rule 57, and that when the attachment ground coincides with the cause of action (fraud), the defendant cannot challenge the writ without trial on the merits. However, the Court held that PNB remained liable for the L/C as no valid substitution of debtor occurred without the creditor's consent, directing the bank to deposit the proceeds in escrow pending final adjudication.