G.R. No. L-19328 - Katigbak vs. Solicitor General

Alejandro Katigbak and Mercedes K. Katigbak (plaintiffs-appellants) filed Civil Case No. 30823 against the Solicitor General and other government officials (defendants-appellees), seeking to enjoin the filing of a forfeiture complaint under Republic Act No. 1379, declare the statute unconstitutional with respect to properties acquired before its approval, exclude certain properties from forfeiture, and claim damages against investigating officers.
The Republic of the Philippines (plaintiff-appellee) filed Civil Case No. 31080 against Alejandro Katigbak, Mercedes Katigbak, and their son Benedicto seeking forfeiture of properties allegedly acquired illegally by Alejandro Katigbak during his government service in accordance with R.A. No. 1379. Some of these properties were recorded under the names of his wife and son.
Both cases were tried jointly in the Court of First Instance of Manila.

The court dismissed the complaint and counterclaim in Civil Case No. 30823.
In Civil Case No. 31080, the court held certain properties acquired in 1953, 1954, and 1955 as subject to a lien in favor of the government in the amount of ₱100,000 (later reduced to ₱80,000 on motion for reconsideration).
The Trial Court found that the investigating prosecutor’s impatience did not invalidate the proceedings since Katigbak fully ventilated his defense.
It held that R.A. No. 1379 is not penal in nature but aimed at recovery of property held under implied trust.
Prescription does not run on properties acquired through delicts.
Katigbak voluntarily testified and was not compelled to self-incriminate.
No malice or bad faith was found against the investigating prosecutor, hence no damages were awarded.

The Katigbaks appealed, raising 18 errors focused mainly on the constitutionality of R.A. No. 1379 as an ex post facto law punishing acquisitions prior to the law’s enactment.
The Court of Appeals certified the issue for the Supreme Court's resolution, specifically whether R.A. No. 1379 (insofar as it authorizes forfeiture of properties acquired before its approval):

Constitutes an ex post facto law compelling self-incrimination and confiscation without due process; and
Permits confiscation of previously good faith mortgaged properties.

Whether Republic Act No. 1379, which authorizes the forfeiture of properties unlawfully acquired by public officials even prior to its enactment, is unconstitutional as an ex post facto law.
Whether the imposition of forfeiture or lien under R.A. No. 1379 violates the constitutional right against self-incrimination by compelling public officers to explain the acquisition of their properties.
Whether forfeiture of properties previously mortgaged in good faith is permissible under R.A. No. 1379.
Whether the investigating prosecutor’s conduct during preliminary investigation was arbitrary or in bad faith so as to warrant damages.