G.R. No. 138894 - Heirs of Marcos vs. Presidential Commission on Good Government

On February 28, 1986, former President Corazon C. Aquino issued Executive Order No. 1 establishing the Presidential Commission on Good Government (PCGG).
The PCGG was created as a collegial body tasked with recovering the ill-gotten wealth amassed by former President Ferdinand E. Marcos, his immediate family, relatives, and close associates, both domestically and internationally.
It was vested with extensive powers, including the takeover or sequestration of business enterprises and entities owned or controlled by the Marcos family and related cronies.

To fulfill its mandate, the PCGG instituted various civil actions for reconveyance, reversion, accounting, restitution, and damages against individuals allegedly holding ill-gotten property.
Among these actions was a suit involving former Ambassador Roberto S. Benedicto, regarded as one of Marcos’ cronies.
On November 3, 1990, Benedicto, along with the Republic of the Philippines, executed a compromise agreement in which he surrendered his 51% equity in Eastern Telecommunications Philippines, Inc. (ETPI), corresponding to 2,652,000 shares (10.2% of the total capital).

The petitioners, identified as the heirs of the late President Ferdinand E. Marcos, alleged ownership over the ETPI shares that Benedicto had surrendered to the PCGG.
On April 17, 1998, petitioners filed a complaint before the Sandiganbayan seeking:

A declaration that the late President Marcos and/or his estate were the true and lawful owners of the shares;
An accounting of the shares; and
Payment of damages (P400,000 for moral damages, P400,000 for exemplary damages, and P200,000 for attorney’s fees) along with the costs of the suit.

During the pre-trial conference scheduled for October 9, 1998, proceedings were held in abeyance due to the petitioners’ alleged nonpayment of the complete docket fee required under Section 7 of Rule 141 of the Revised Rules of Court and Section 4 of Republic Act No. 7975.
On October 14, 1998, an order was issued in open court by the Sandiganbayan directing the petitioners to show cause why their complaint should not be dismissed for lack of jurisdiction, given their failure to pay the additional required filing fee amounting to P1,326,955.00 Pesos.
Petitioners, after requesting an extension, filed a response on November 17, 1998, arguing:

The application of Section 7 of Rule 141 in connection with Section 4 of R.A. No. 7975 would result in an unconstitutional diminution of their substantive rights under Section 11 of P.D. No. 1606.
That the subsequent laws (R.A. Nos. 7975 and 8249) did not expressly or impliedly repeal Section 11 of P.D. No. 1606.
That because the Sandiganbayan is of the same level as the Court of Appeals, Sections 4 and 5 of Rule 141 should accordingly apply.

On February 15, 1999, the Sandiganbayan dismissed the complaint for lack of jurisdiction on the ground that the correct filing fees were not paid.
Petitioners filed a motion for reconsideration on March 10, 1999, which was later denied by the Sandiganbayan on May 24, 1999.

The petitioners also raised issues regarding the alleged accumulation of rights over the shares, contending that their claim potentially accrued on either November 3, 1990, or on September 10, 1993.
It was noted that even if the claim were timely, the ten (10) year prescriptive period under Article 1144 of the Civil Code had already elapsed, thus barring their right of action.

Whether the Sandiganbayan erred in dismissing the petitioners’ complaint for lack of jurisdiction due to nonpayment of the correct and additional filing fee as prescribed by Section 7 of Rule 141 of the Revised Rules of Court.
Whether the rules on filing fees applicable to lower courts (such as Regional Trial Courts) should be applied to the Sandiganbayan, or if instead, the provisions applicable to the Court of Appeals (Sections 4 and 5 of Rule 141) would be appropriate because of their equivalence in level.

Whether applying Section 7 of Rule 141 (in conjunction with Section 4 of R.A. No. 7975) to the case would unconstitutionally alter or diminish the petitioners’ substantive rights guaranteed under Section 11 of P.D. No. 1606.
Whether the subsequent amendments through R.A. Nos. 7975 and 8249 impliedly repealed or modified the provisions of P.D. No. 1606, thereby justifying the imposition of filing fees even in cases originally intended to be free of charge.

Whether the alleged recovery claim, particularly for the shares surrendered under the compromise agreement, fell within the ten-year prescriptive period as mandated by Article 1144 of the Civil Code.