Case Digest (G.R. No. 213027)
Facts:
In Republic of the Philippines v. Estate of Ferdinand E. Marcos (represented by his Estate/Heirs) and Imelda Romualdez Marcos and Irene Marcos Araneta, G.R. Nos. 213027 & 213253, decided on January 18, 2017, the Sandiganbayan, Special Division in Civil Case No. 0141 granted a Partial Summary Judgment (13 January 2014) and denied motions for reconsideration (11 June 2014), declaring the Malacañang Collection of jewelry ill-gotten under Republic Act No. 1379 and forfeited in favor of the Republic. The case traces back to a 1991 petition filed by the Presidential Commission on Good Government (PCGG) through the Office of the Solicitor General, seeking recovery of assets allegedly acquired by Ferdinand E. Marcos and Imelda R. Marcos through improper or illegal use of public funds. The petition itemized eighteen categories of properties, including paintings, silverware, and jewelry seized at Malacañang Palace and turned over by the United States. In 2009 the Republic moved for partiaCase Digest (G.R. No. 213027)
Facts:
- Antecedent Facts
- On December 17, 1991, the Republic (through PCGG/OSG) filed Civil Case No. 0141 under R.A. 1379 and E.O. Nos. 1, 2, 14, and 14 A against Ferdinand E. Marcos (Estate/Heirs), Imelda R. Marcos, and others.
- The 1991 petition excluded properties already subject of other forfeiture cases and listed 18 categories of assets, including the “Malacañang Collection” of jewelry under paragraph 9(6).
- Prior forfeiture rulings:
- Republic v. Sandiganbayan (2003) – Swiss bank deposits forfeited.
- Marcos v. Republic (2012) – Arelma funds and properties forfeited.
- Motion for Partial Summary Judgment on Malacañang Collection
- June 24, 2009 – Republic filed a Motion for Partial Summary Judgment declaring the Malacañang Collection (¶ 9(6)) ill-gotten; valued at US $110,055–153,089 by Christie’s.
- July 3, 2009 – Republic served a Request for Admission on the Estate, Imelda, and Irene Marcos covering:
- Acquisition during incumbency (1966–1986).
- Purchase abroad (Asia, Europe, U.S.).
- Correspondence of acquisition costs to Christie’s 1998 appraisal.
- Mint condition status at recovery.
- July 14, 2009 – Supplement to motion with PCGG custodian’s affidavit attaching detailed appraisals (Honolulu, Roumeliotes, Malacañang collections) and invoices from Gemsland.
- Respondents’ Pleadings and Sandiganbayan Proceedings
- July 21, 2009 – Imelda and Irene Marcos filed Manifestation and Preliminary Comments demanding return of jewelry, asserting lack of forfeiture proceedings or sequestration order.
- July 25, 2009 – Motion to Expunge Request for Admission as inconsistent and prematurely filed; sought ocular inspection.
- August 2, 2010 – Sandiganbayan denied objections, held proceedings not terminated, and directed respondents to answer admissions; respondents did not comply.
- January 13, 2014 – Sandiganbayan issued Partial Summary Judgment:
- Jurisdiction proper.
- Malacañang Collection included in 1991 petition.
- Summary judgment proper; forfeiture justified under R.A. 1379.
- June 11, 2014 – Sandiganbayan denied motions for reconsideration.
- Supreme Court Proceedings
- June–November 2014 – Estate and Imelda/Irene Marcos filed extensions, unified petitions for review under Rule 45.
- November 17, 2014 – SC consolidated G.R. Nos. 213027 and 213253.
Issues:
- Did the Sandiganbayan have jurisdiction over the Malacañang Collection?
- Was the Malacañang Collection properly included in the 1991 forfeiture petition?
- Was forfeiture of the Collection justified under R.A. 1379?
- Was the Request for Admission inconsistent with the Motion for Partial Summary Judgment?
- Did the summary judgment and forfeiture violate petitioners’ right to due process?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)