Facts:

The case involves the Estate of Ferdinand E. Marcos and Imelda Romualdez Marcos as petitioners against the Republic of the Philippines as the respondent. The proceedings stem from Civil Case No. 0141, a forfeiture case initiated by the Republic through the Presidential Commission on Good Government (PCGG) on December 17, 1991. The case sought the recovery of assets and properties allegedly acquired by the Marcoses through the illegal use of government funds. Among the properties listed was the Malacañang Collection of jewelry, which was specifically mentioned in the 1991 Petition. The Sandiganbayan, in its Partial Summary Judgment dated January 13, 2014, ruled that the Malacañang Collection was ill-gotten and ordered its forfeiture in favor of the Republic. The ruling was based on the premise that the legitimate income of the Marcoses during their incumbency was grossly disproportionate to the value of the jewelry collection. The Sandiganbayan also noted that the Marcoses had...

Facts:

Background of the Case:
Civil Case No. 0141 is a forfeiture case filed by the Republic of the Philippines against the Estate of Ferdinand E. Marcos and Imelda R. Marcos. The case was initiated on December 17, 1991, under Republic Act No. 1379, seeking the recovery of assets and properties allegedly acquired by the Marcoses through improper or illegal use of government funds. The properties were categorized into 18 groups, including the Malacañang Collection of jewelry.

Previous Forfeiture Cases:
Prior to this case, other properties of the Marcoses had already been declared ill-gotten and forfeited in favor of the government, such as the Swiss deposits in 2003 and the Arelma funds in 2012.

The Malacañang Collection:
The Malacañang Collection consists of jewelry seized from Malacañang Palace after the EDSA Revolution in 1986. The Republic filed a Motion for Partial Summary Judgment on June 24, 2009, seeking to declare the jewelry as ill-gotten and to forfeit it in favor of the government. The Republic argued that the Marcoses' lawful income was grossly disproportionate to the value of the jewelry.

Request for Admission:
On July 3, 2009, the Republic filed a Request for Admission, asking the Marcoses to admit that the Malacañang Collection was acquired during their incumbency as public officials and that its value corresponded to the appraisals by Christie’s. The Marcoses failed to respond to this request.

Sandiganbayan Ruling:
The Sandiganbayan issued a Partial Summary Judgment on January 13, 2014, declaring the Malacañang Collection as ill-gotten and ordering its forfeiture in favor of the Republic. This decision was affirmed in a Resolution dated June 11, 2014, after the Marcoses' motions for reconsideration were denied.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Jurisdiction: The Sandiganbayan has jurisdiction over the properties listed in the 1991 forfeiture petition, including the Malacañang Collection, which was specifically mentioned in the petition.
2. Forfeiture under R.A. 1379: The law presumes that properties acquired by public officers disproportionate to their lawful income are ill-gotten. The Marcoses failed to rebut this presumption.
3. Consistency of Pleadings: A request for admission can complement a motion for summary judgment. The Marcoses' failure to respond to the request resulted in the admission of the facts contained therein.
4. Due Process: The Marcoses were given ample opportunities to present their case and failed to demonstrate that the jewelry was lawfully acquired. The extensive records and pleadings in the case confirm that due process was observed.

The Supreme Court affirmed the Sandiganbayan's Partial Summary Judgment and Resolution, declaring the Malacañang Collection as ill-gotten and forfeiting it in favor of the Republic.