Facts:

• The case involves the Republic of the Philippines as the petitioner against the Honorable Sandiganbayan and respondents Ferdinand E. Marcos and his heirs.
• The Supreme Court decided the case on November 18, 2003, following motions for reconsideration from the respondents regarding a prior decision dated July 15, 2003.
• The earlier decision ordered the forfeiture of Swiss deposits held in escrow at the Philippine National Bank, amounting to approximately US$658,175,373.60 as of January 31, 2002.
• Respondents argued that the forfeiture proceedings under Republic Act No. 1379 were criminal, asserting their rights to due process, including the presumption of innocence and the burden of proof on the prosecution.
• They claimed the summary judgment by the Sandiganbayan was improper and that they were denied the chance to present evidence and witnesses.

Issue:

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Ruling:

• The Supreme Court ruled that the decision did not deprive the respondents of their right to due process.
• The Court affirmed that summary judgment is applicable in forfeiture proceedings under Republic Act No. 1379.
• The Court held that forfeiture proceedings are civil in nature, not criminal....(Unlock)

Ratio:

• The Supreme Court stated that due process includes both substantive and procedural elements.
• The Court determined that forfeiture proceedings under Republic Act No. 1379 are civil, lacking the same constitutional protections as criminal cases.
• The burden of proof shifted to the respondents once the Republic established a prima facie case of illegal property acquisition.
• Summary judgment is a valid procedural tool when no genuine...continue reading