Title
Estate of Marcos vs. Republic
Case
G.R. No. 213027
Decision Date
Jan 18, 2017
The Republic sought forfeiture of the Marcoses' Malacañang jewelry, deemed ill-gotten under R.A. 1379, as their lawful income was disproportionate. SC upheld Sandiganbayan's ruling, affirming forfeiture.
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Case Summary (G.R. No. 213027)

Jurisdiction of the Sandiganbayan

  • The Sandiganbayan correctly acquired jurisdiction over the case concerning the Malacañang Collection.
  • The properties in question were included in the 1991 Petition, specifically referenced in subparagraph (6) of paragraph (9).
  • The 1991 Petition categorically alleged that the Malacañang Collection was part of the assets sought for recovery.
  • The Sandiganbayan noted that the petition complied with the requirements of the Rules of Court regarding the sufficiency of allegations.

Forfeiture Justification Under R.A. 1379

  • The Sandiganbayan ruled that the forfeiture of the Malacañang Collection was justified under R.A. 1379.
  • The legitimate income of the Marcoses was determined to be USD 304,372.43, which was grossly disproportionate to the value of the jewelry.
  • The presumption of unlawfully acquired property applies when public officials acquire property that is manifestly out of proportion to their lawful income.

Consistency of Requests and Motions

  • The Sandiganbayan found no inconsistency between the Republic's Request for Admission and the Motion for Partial Summary Judgment.
  • A request for admission can serve as a basis for granting summary judgment if the subject matter is deemed admitted due to a party's failure to respond.
  • The Sandiganbayan correctly granted the Republic's Motion for Summary Judgment based on the Marcoses' failure to respond to the Request for Admission.

Due Process Considerations

  • The petitioners' claims of lack of due process were deemed belated and unsubstantiated.
  • The Marcoses had numerous opportunities to prove the lawful acquisition of the Malacañang Collection throughout the proceedings.
  • The complete records of Civil Case No. 0141 were forwarded to the Court, ...continue reading

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