Case Digest (G.R. No. 152154) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On December 17, 1991, the Republic of the Philippines (through the PCGG and Office of the Solicitor General) filed a civil forfeiture petition under R.A. No. 1379 against former President Ferdinand E. Marcos (deceased, represented by his estate/heirs: Imelda R. Marcos, Imee Marcos-Manotoc, Ferdinand R. Marcos, Jr., Irene Marcos-Araneta) and Imelda R. Marcos before the Sandiganbayan Special First Division (Civil Case No. 0141). The Republic sought to declare as ill-gotten wealth approximately US $356 million (later accrued to US $658 million) held in escrow at the Philippine National Bank, representing deposits originally frozen in Swiss banks under five foundation groups. After respondents answered on October 18, 1993, the Sandiganbayan conducted pre-trial proceedings and denied petitioner’s 1996 motion for summary judgment due to pending compromise agreements. Following further motions and supervisory appeals in Switzerland, the Swiss deposits were transferred to PNB escrow in Case Digest (G.R. No. 152154) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties
- Petitioner: Republic of the Philippines, represented by the Presidential Commission on Good Government (PCGG) and Office of the Solicitor General (OSG)
- Respondents: Sandiganbayan (Special First Division), Ferdinand E. Marcos (deceased, represented by estate/heirs) and Imelda R. Marcos
- Background
- On December 17, 1991, PCGG filed Civil Case No. 0141 for forfeiture under R.A. 1379 and related Executive Orders, seeking US$356 M (later US$658 M with interest) held in five Swiss-foundation account groups and US$30 M in treasury notes.
- Respondents answered on October 18, 1993, denying ownership/knowledge of the funds.
- December 28, 1993: Marcos children executed a General Agreement and Supplemental Agreements with PCGG for a global settlement, later declared void.
- Procedural History
- October 18, 1996: Republic moved for summary judgment; denied for pending compromise approval.
- March 10, 2000: Republic filed renewed motion for summary judgment, supported by schedules of lawful income and detailed evidence of Swiss accounts. Respondents opposed with general denials, no affidavits.
- September 19, 2000: Sandiganbayan granted summary judgment; declared US$627 M forfeited.
- September 26 & October 5/9, 2000: Respondents moved for reconsideration, adopted by co-respondents.
- January 31, 2002: Sandiganbayan reversed itself, set case for further proceedings due to lack of authenticated Swiss decisions/translations.
- Republic filed Rule 65 certiorari petition with the Supreme Court.
Issues:
- Propriety of summary judgment
- Did respondents raise genuine issues of material fact to preclude summary judgment under Rule 35?
- Was the timing of Republic’s summary judgment motion (“any time after answer served”) proper?
- Prima facie case for forfeiture under R.A. 1379
- Did petitioner prove (a) respondents’ ownership of funds and (b) disproportion between Swiss deposits and known lawful income?
- Were respondents required to show other lawful income or file Statements of Assets and Liabilities?
- Could foreign foundations be impleaded as indispensable parties?
- Did lack of authenticated translations of Swiss court decisions warrant reversal?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)