Marcos v. Republic
REITERATIONFacts
The Antecedents: The Republic of the Philippines, through the Presidential Commission on Good Government (PCGG), filed a Petition dated December 17, 1991 (1991 Petition) seeking the recovery of assets and properties allegedly acquired directly or indirectly through improper or illegal use of government funds or properties by the Marcoses, pursuant to Republic Act No. 1379 and Executive Orders 1, 2, 14, and 14-A. Some properties were excluded as they were subjects of other pending forfeiture cases, while others were specifically listed and clustered. Certain properties, like Swiss bank deposits and Arelma funds, had already been declared ill-gotten and forfeited in prior cases. Procedural History: The Republic filed a Motion for Partial Summary Judgment on June 24, 2009, seeking to declare the pieces of jewelry known as the Malacañang Collection, listed under paragraph 9(6) of the 1991 Petition, as ill-gotten and subject to forfeiture. The Republic argued that the Marcoses' claim of ownership, their use of a "negative pregnant" in their Answer, and the disproportionate value of the jewelry to their lawful income supported the motion. The Republic also filed a Request for Admission on July 3, 2009, seeking admissions regarding the acquisition of the Malacañang Collection. Imelda Marcos and Irene Marcos Araneta filed various pleadings, including a Manifestation and Preliminary Comments and a Manifestation and Motion to Expunge, arguing against the motion and the request for admission. The Sandiganbayan denied these motions and directed the Marcoses to respond to the Request for Admission, which they failed to do. Subsequently, the Sandiganbayan issued a Partial Summary Judgment dated January 13, 2014, declaring the Malacañang Collection subject to forfeiture. Motions for Reconsideration were denied by the Sandiganbayan in a Resolution dated June 11, 2014. The Petition: The Estate of Ferdinand Marcos and Imelda Romualdez Marcos and Irene Marcos Araneta filed Petitions for Review on Certiorari assailing the Partial Summary Judgment and Resolution of the Sandiganbayan, which were consolidated by the Supreme Court.
Issue(s)
Whether the Sandiganbayan has jurisdiction over the properties. Whether the Malacañang Collection can be the subject of the forfeiture case. Whether forfeiture is justified under R.A. 1379. Whether the Sandiganbayan correctly ruled that the Motion for Partial Summary Judgment was not inconsistent with the Request for Admission. Whether the Sandiganbayan correctly declared that the forfeiture was not a deprivation of petitioners' right to due process of law.
Ruling
The Supreme Court affirmed the Partial Summary Judgment dated January 13, 2014, and the Resolution dated June 11, 2014, rendered by the Sandiganbayan in Civil Case No. 0141, declaring the Malacañang Collection as ill-gotten wealth and forfeiting it in favor of the Republic.
Ratio Decidendi
On the jurisdiction over the properties: The Sandiganbayan correctly acquired jurisdiction because the Malacañang Collection was explicitly included in the 1991 Petition under paragraph 9(6), which referred to jewelries and other valuable decorative arts found in Malacañang and estimated to be about $23.9-M, with detailed listings in annexed documents. These annexes were made an integral part of the petition, thus sufficiently stating a cause of action for forfeiture under Section 3(d) of R.A. 1379. The Court reiterated that the test for sufficiency of an initiatory pleading is whether, admitting the truth of the facts alleged, the court can render a valid judgment in accordance with the prayer, considering only material allegations and appended documents. On whether the Malacañang Collection can be the subject of the forfeiture case: The Malacañang Collection was properly included as a subject of the forfeiture case. The 1991 Petition, by referencing Annexes "F-1," "F-2," "F-2-a," and "F-3," which itemized the pieces of jewelry, sufficiently alleged that these items were part of the assets sought to be recovered. The Court found that the petition categorically alleged the inclusion of the Malacañang Collection among the assets subject to forfeiture. The subsequent motion for partial summary judgment specifically targeted this collection, which was consistent with the original petition's scope. On whether forfeiture is justified under R.A. 1379: The forfeiture was justified under R.A. 1379 due to the prima facie presumption of unlawful acquisition. The Court noted that the legitimate income of the Marcoses during their incumbency was pegged at USD 304,372.43, which was manifestly disproportionate to the value of the Malacañang Collection. Petitioners failed to satisfactorily show that the properties were lawfully acquired, thus the presumption that they were unlawfully acquired prevailed. This aligns with the established jurisprudence that property acquired during incumbency, disproportionate to lawful income, is presumed unlawfully acquired. On whether the Sandiganbayan correctly ruled that the Motion for Partial Summary Judgment was not inconsistent with the Request for Admission: The Sandiganbayan correctly ruled that the Request for Admission did not render the Motion for Partial Summary Judgment inconsistent. The Court held that a request for admission can serve as a basis for summary judgment, especially when the matters contained therein are deemed admitted due to a failure to respond. The resort to this mode of discovery was intended to elicit details and expedite the resolution of the motion, not to create new issues. The failure of the Marcoses to respond to the Request for Admission meant that the matters contained therein were deemed admitted by operation of law. On whether the Sandiganbayan correctly declared that the forfeiture was not a deprivation of petitioners' right to due process of law: The invocation of lack of due process was deemed belated and baseless. The petitioners had numerous opportunities to prove the lawful acquisition of the Malacañang Collection through various pleadings filed in this case and other related cases. The Court emphasized that the records of Civil Case No. 0141, including the annexes and pleadings, were extensively reviewed and quoted in the resolution, demonstrating that the petitioners were not denied an opportunity to present their case. The procedural steps taken, including the opportunity to respond to the Request for Admission, satisfied the requirements of due process.
Main Doctrine
The Sandiganbayan correctly granted the Republic's Motion for Partial Summary Judgment to forfeit the Malacañang Collection as ill-gotten wealth, based on the prima facie presumption of unlawful acquisition due to disproportionate assets, the respondents' 'negative pregnant' answer, and their failure to respond to the Request for Admission, thereby deeming the matters therein admitted.