Title
Marcos vs. Sandiganbayan
Case
G.R. No. 126995
Decision Date
Oct 6, 1998
Imelda Marcos acquitted as prosecution failed to prove she acted as a public officer or that the lease agreement was grossly disadvantageous to the government.

Case Digest (G.R. No. 1786)
Expanded Legal Reasoning Model

Facts:

  • Parties and Indictment
    • Imelda R. Marcos (petitioner) and Jose P. Dans, Jr. (co-accused) served as ex officio Chair and Vice-Chair, respectively, of the Light Rail Transit Authority (LRTA).
    • Indicted under Section 3(g) of RA 3019 (Anti-Graft and Corrupt Practices Act) for conspiring to enter a manifestly and grossly disadvantageous Lease Agreement on or about June 8, 1984.
  • Lease and Sublease Agreements
    • Lease Agreement (Exh. “B”): LRTA leased 7,340 sqm in Pasay City to the Philippine General Hospital Foundation, Inc. (PGHFI) for ₱102,760/month over 25 years; signed by Dans for LRTA and Marcos for PGHFI.
    • Sublease Agreement (Exh. “D”): PGHFI subleased the same lot to Transnational Construction Corporation (TNCC) for ₱734,000/month over 25 years; signed by Marcos for PGHFI and TNCC’s president.
  • Procedural History in Sandiganbayan
    • First Division (Justices Garchitorena, Balajadia, Atienza) failed to reach a unanimous vote.
    • Presiding Justice Garchitorena formed a five-member Special Division (Adm. Order No. 288-93); dissolved it (Adm. Order No. 293-93) after an informal lunch meeting of three justices.
    • On September 24, 1993, the reconstituted First Division convicted both Marcos and Dans.
  • Supreme Court Review
    • On January 29, 1998, the Third Division affirmed Marcos’s conviction (G.R. No. 126995) but reversed Dans’s (G.R. No. 127073), relying mainly on the rental disparity.
    • Marcos filed a Motion for Reconsideration (MFR), raising (a) lack of proof she acted as a public officer; (b) insufficient evidence of gross disadvantage; (c) due process violations; and (d) right to speedy disposition.
    • The Court en banc heard oral arguments on September 10, 1998, and invited memoranda.

Issues:

  • Public-Officer Element
Did Marcos “enter, on behalf of the Government,” into the Lease Agreement as required by Sec. 3(g), RA 3019?
  • Gross-Disadvantage Element
Did the prosecution prove beyond reasonable doubt that the Lease Agreement was manifestly and grossly disadvantageous to the Government?
  • Procedural Due Process
Were Marcos’s rights violated by the irregular formation and premature dissolution of the Special Division in the Sandiganbayan?
  • Speedy-Disposition Right
Would remanding the case for a new decision violate Marcos’s constitutional right to a speedy disposition of her case?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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