Case Digest (G.R. No. 174673)
Facts:
Republic of the Philippines v. Fe Roa Gimenez and Ignacio B. Gimenez, G.R. No. 174673, January 11, 2016, Supreme Court Second Division, Leonen, J., writing for the Court. The Presidential Commission on Good Government (PCGG) instituted a civil forfeiture Complaint for Reconveyance, Reversion, Accounting, Restitution and Damages against spouses Fe Roa Gimenez and Ignacio B. Gimenez before the Sandiganbayan, alleging they were dummies/nominees of Ferdinand and Imelda Marcos and had accumulated wealth grossly disproportionate to lawful income. The Republic presented documentary exhibits and five witnesses (including Atty. Tereso Javier and Danilo R.V. Daniel) over a protracted 19‑year trial.After the Republic rested, the Sandiganbayan set a 30‑day period (until March 29, 2006) for the filing of a written Formal Offer of Evidence; two extensions (to April 28 and May 13, 2006) were later granted. When the Republic did not file the Formal Offer by May 13, 2006 the Sandiganbayan issued a May 25, 2006 Resolution deeming the Formal Offer waived and directing reception of defendants’ evidence. Respondent Ignacio filed a Demurrer to Evidence (May 30, 2006) and Fe Roa moved to dismiss for failure to prosecute (June 13, 2006). On June 15, 2006 the Republic filed a Motion for Reconsideration attaching a belated Formal Offer of Evidence consisting of voluminous documentary exhibits (bank statements, certified copies of titles and corporate records, affidavits and PCGG memoranda).
In its September 13, 2006 Resolution the Sandiganbayan denied the motion for reconsideration, reiterated that the Republic had waived its Formal Offer after repeated extensions and long delay, discounted much of the documentary exhibits as uncertified photocopies lacking probative value, granted the Demurrer to Evidence and dismissed the case. The Republic filed a Petition for Review on Certiorari under Rule 45 with the Supreme Court challenging both the Sandiganbayan’s deeming of waiver and the dismissal. The Supreme Court required m...(Pro-only)
Issues:
- Was a Petition for Review on Certiorari under Rule 45 the proper remedy to assail the Sandiganbayan Resolutions?
- Did the Sandiganbayan commit reversible error in deeming the Republic to have waived its Formal Offer of Evidence and in granting the defendants’ Motion to Dismiss on ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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