Case Digest (G.R. No. 171701)
Facts:
Republic of the Philippines v. Ma. Imelda "Imee" R. Marcos-Manotoc, Ferdinand "Bongbong" R. Marcos, Jr., Gregorio Ma. Araneta III, Irene R. Marcos-Araneta, Yeung Chun Fan, Yeung Chun Ho, Yeung Chun Kam, and Pantranco Employees Association (PEA)-PTGWO, G.R. No. 171701, February 08, 2012, the Supreme Court Second Division, Sereno, J., writing for the Court.After the 1986 EDSA Revolution the Presidential Commission on Good Government (PCGG) was created by Executive Order No. 1 to recover alleged ill-gotten wealth of Ferdinand E. Marcos, his family and associates. Acting for the Republic and assisted by the Office of the Solicitor General (OSG), the PCGG filed Civil Case No. 0002 on 16 July 1987 seeking reversion, reconveyance, restitution, accounting and damages against Ferdinand E. Marcos (later substituted by his estate), Imelda R. Marcos and numerous relatives, associates and corporate entities. The Complaint was amended several times to add additional defendants, including the Yeungs and Prime Holdings, Inc.; a fourth amended complaint was later denied by the Sandiganbayan.
The Complaint alleged P200 billion in ill-gotten wealth, dollar-salting through garment companies (e.g., De Soleil Apparel and Glorious Sun), use of broadcast networks (IBC-13, BBC-2, RPN-9) for private benefit, and the illegal acquisition/operation of Pantranco North Express, Inc. The Pantranco Employees Association-PTGWO (PEA-PTGWO) intervened, claiming that certain Pantranco trust funds (≈P55 million) belonged to employees under an NLRC money judgment.
During pretrial and trial the PCGG/OSG offered numerous documentary exhibits (notably Exhibits “P,” “Q,” “R,” “S,” and “T” — affidavits and a transcript of stenographic notes), many of which were photocopies or unauthenticated. On 11 March 2002 the Sandiganbayan admitted the prosecution’s documentary exhibits but reserved their evidentiary value. Respondents thereafter filed Demurrers to Evidence. On 6 December 2005 the Sandiganbayan granted all demurrers except Imelda Marcos’s, finding a prima facie case against Imelda due to her admissions and the gross disproportion of assets; it granted the demurrers of Imee and Bongbong Marcos, Irene and Gregorio Araneta, the Yeungs, and intervenor PEA-PTGWO largely because the prosecution failed to present originals or witnesses and thus the documents were inadmissible hearsay or violative of the best evidence rule.
The Republic moved for partial reconsideration, contending the Sandiganbayan erred in granting demurrers and in excluding or devaluing evidence, and argued that the Marc...(Pro-only)
Issues:
- Did the Sandiganbayan err in granting the Demurrers to Evidence of respondents Imee Marcos-Manotoc, Ferdinand R. Marcos, Jr. (Bongbong), Irene Marcos-Araneta and Gregorio Ma. Araneta III?
- Did the Sandiganbayan err in denying Imelda R. Marcos’s Demurrer to Evidence?
- Were the Yeung respondents shown to be dummies used for dollar salting such that the Sandiganbayan erred in granting their Demurrers to Evidence?
- Did the Sandiganbayan err in granting the Demurrer to Evidence of intervenor PEA-PTGWO regarding the Pantranco assets?
- Did the Sandiganbayan’s admission of documentary exhibits in 2002 and later exclusion/devaluati...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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