Case Digest (G.R. No. 152154)
Facts:
Republic of the Philippines v. Honorable Sandiganbayan (Special First Division), G.R. No. 152154, July 15, 2003, Supreme Court En Banc, Corona, J., writing for the Court.Petitioner Republic of the Philippines, through the Presidential Commission on Good Government (PCGG) and the Office of the Solicitor General, filed on December 17, 1991 a petition for forfeiture under R.A. No. 1379 (Civil Case No. 0141) against Ferdinand E. Marcos (represented by his estate/heirs: Imelda R. Marcos, Maria Imelda [Imee] Marcos‑Manotoc, Ferdinand R. Marcos, Jr., and Irene Marcos‑Araneta) and Imelda Romualdez Marcos, seeking forfeiture of funds originally identified as roughly US$356 million (later estimated, with interest, at US$658,175,373.60) held in various Swiss foundations and remitted in escrow to the Philippine National Bank (PNB), plus certain Central Bank treasury notes.
Respondents filed an answer (October 18, 1993). While the case was pending, the Marcos children and the PCGG executed a General Agreement and Supplemental Agreements (December 28, 1993) seeking a global settlement; respondents later moved to have those agreements approved. Petitioner sought judicial assistance in Switzerland, obtained orders blocking and ultimately transferring the Swiss deposits to escrow in the PNB (December 10, 1997 Swiss Federal Supreme Court decision), and the funds were remitted in 1998 and placed in custodia legis by Sandiganbayan resolution (September 8, 1998).
After pre‑trial, petitioner moved for summary judgment (October 18, 1996 and again March 10, 2000). The Sandiganbayan initially denied the 1996 motion because the compromise agreement took precedence, but after hearing the 2000 motion it granted summary judgment in a September 19, 2000 decision, declaring the Swiss deposits (then valued at US$627,608,544.95 as of August 31, 2000) forfeited to the State. Respondents filed motions for reconsideration. In a January 31, 2002 resolution the Sandiganbayan reversed its September 19, 2000 decision, concluded petitioner had not established ownership of the funds by the Marcoses because the authenticated Swiss decisions and translations were not submitted, and set the case for further proceedings.
Petitioner filed a Rule 65 petition for certiorari before the Supreme Court to set aside the Sandiganbayan’s January 31, 2002 resolution and to reinstate the September 19, 2000 forfeiture decision. The Solicitor General advanced (inter alia) that respondents’ pleadings and subsequent submissions contained judicial admissions and that respondents raised no genuine issue of fact to defeat summary judgment under Rule 35; respondents opposed, arguing certiorari was improper because an adequate remedy existed in the Sandiga...(Pro-only)
Issues:
- Was certiorari under Rule 65 a proper mode of review of the Sandiganbayan’s January 31, 2002 resolution?
- Did respondents raise any genuine issue of fact sufficient to defeat petitioner’s motion for summary judgment under the Rules of Court?
- Did petitioner prove a prima facie case for forfeiture under R.A. No. 1379, Sections 2 and 3 (and, if so, was forfei...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)