Title
Supreme Court
Garcia vs. Sandiganbayan
Case
G.R. No. 167103
Decision Date
Aug 31, 2006
A forfeiture case against Garcia, et al., dismissed due to procedural defects in their motion, upheld by the Supreme Court.

Case Summary (G.R. No. 71980)

Petitions Filed

A petition for forfeiture was filed on October 27, 2004, by the Ombudsman against the Garcia family. Garcia filed a Motion to Dismiss on November 17, 2004, citing lack of jurisdiction of the Sandiganbayan over such forfeiture actions. Concurrently, he filed a petition for certiorari before the Supreme Court (G.R. No. 165835), questioning the Sandiganbayan's jurisdiction. The Supreme Court ruled on this petition on July 22, 2005, affirming Sandiganbayan’s jurisdiction.

Motion to Dismiss and Default Rulings

The Sandiganbayan addressed the Republic’s motion to expunge the Garcia family's Motion to Dismiss, which was deemed defective for lacking proper notice of hearing, contravening Section 5, Rule 15 of the Rules of Court. Consequently, the Sandiganbayan declared Garcia et al. in default and scheduled the case for ex parte hearings.

Sandiganbayan's Jurisdiction

The Sandiganbayan confirmed its jurisdiction over petitions for property forfeiture under R.A. No. 1379, stating that the authority to file such actions belongs to the Office of the Ombudsman for properties acquired after February 25, 1986. The resolution affirmed that a procedural defect in the Motion to Dismiss did not halt the requirement for a timely response from Garcia et al.

Appeals and Arguments

Garcia’s Motion for Reconsideration was filed on January 25, 2005, arguing that the failure to answer was impacted by the pending petition at the Supreme Court (G.R. No. 165835). The Sandiganbayan, however, ruled that the principle of judicial courtesy did not apply since the motion was procedurally defective and did not cite any legitimate reason for default relief.

Supreme Court Review

In his petition to the Supreme Court, Garcia asserted that the Sandiganbayan's refusal to acknowledge his Motion to Dismiss, which he alleged was timely and compliant with due process, was erroneous. He claimed that he deserved an extension to file an answer due to the time needed to accommodate the dismissal of his motion.

Final Determination

The Supreme Court found no merit in Garcia's claims regarding timely filing of the motion to dismiss.

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