Case Digest (G.R. No. 213027)
Facts:
Estate of Ferdinand E. Marcos v. Republic of the Philippines, G.R. No. 213027, and Imelda Romualdez Marcos and Irene Marcos Araneta v. Republic of the Philippines, G.R. No. 213253, January 18, 2017, Supreme Court First Division, Sereno, C.J., writing for the Court. The petitions seek review of the Sandiganbayan Special Division’s Partial Summary Judgment dated 13 January 2014 and Resolution dated 11 June 2014 in Civil Case No. 0141, which declared the pieces of jewelry collectively known as the Malacanang Collection ill-gotten and forfeited in favor of the Republic.The underlying action began with a forfeiture petition filed on 17 December 1991 by the Republic, through the Presidential Commission on Good Government (PCGG) and the Office of the Solicitor General (OSG), under R.A. No. 1379, seeking recovery of assets alleged to have been illegally acquired by former President Ferdinand E. Marcos, Imelda R. Marcos, their relatives and associates. The 1991 Petition listed and annexed numerous properties clustered into 18 categories (paragraphs 8–9 and annexes), including jewelry and decorative arts identified in Annexes F-1, F-2, F-2-a and F-3, which the PCGG said were part of the Malacanang and related collections.
Some items in the 1991 petition had been the subject of earlier rulings: the Court in Republic v. Sandiganbayan (the Swiss deposits case) (2003) adjudged certain Swiss deposits as ill-gotten; the Court’s Second Division later declared Arelma assets ill-gotten in Marcos v. Republic (2012). In June 2009 the Republic filed a Motion for Partial Summary Judgment in Civil Case No. 0141 seeking a judicial declaration that the Malacanang Collection (identified in paragraph 9(6) of the 1991 Petition and appraised by Christie’s and Sotheby’s) was ill-gotten and should be forfeited. The motion attached inventories and appraisals showing the collection’s estimated value and relied on Imelda Marcos’s 25 May 2009 demand letter claiming ownership, the Marcoses’ earlier generic denials in their Answer, and the prima facie presumption arising from the disproportion between the Marcoses’ lawful income and the value of the properties.
On 3 July 2009 the Republic served a Request for Admission under Rule 26, Section 2, seeking admissions about the Malacanang Collection’s acquisition during the Marcos incumbency, acquisition abroad, correspondence with Christie’s appraisals, and condition at recovery. The Marcos respondents filed Manifestations, Preliminary Comments, and a Motion to Expunge (July 2009), arguing among other things that the collection was not specifically prayed for in the 1991 Petition, that the Request for Admission was inconsistent with the Motion for Partial Summary Judgment, and that the Request was untimely or improper. The Sandiganbayan, however, denied the Marcoses’ objections in a Resolution of 2 August 2010, directed them to file sworn answers to the Request for Admission, and later noted their failure to comply.
After memoranda and supplemental pleadings, the Sandiganbayan issued Partial Summary Judgment on 13 January 2014 finding (1) the Malacanang Collection was included in the 1991 Petition; (2) the Motion for Partial Summary Judgment was proper; and (3) forfeiture was justified under R.A. No. 1379. Motions for reconsideration by the Estate and by Imelda Marcos and Irene Araneta w...(Subscriber-Only)
Issues:
- Did the Sandiganbayan have jurisdiction over the Malacanang Collection as included in the 1991 Petition?
- Can the Malacanang Collection be the subject of the forfeiture proceedings in Civil Case No. 0141?
- Was forfeiture of the Malacanang Collection justified under R.A. No. 1379?
- Was the Sandiganbayan correct in ruling that the Republic’s Request for Admission was not inconsistent with its Motion for Partial Summary Judgment?
- Did the Sandiganbayan’s grant of partial summary judgment and relate...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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