Case Summary (G.R. No. 189434)
Background of the Case
On April 25, 2012, the Supreme Court of the Philippines affirmed the Sandiganbayan's decision dated April 2, 2009, declaring that all assets owned by Arelma, S.A., linked to the late Ferdinand E. Marcos, were forfeited in favor of the Republic of the Philippines. The Sandiganbayan based its ruling on the disproportionate wealth of the Marcos spouses relative to their legal incomes and found that the petitioners failed to refute the presumption of ill-gotten wealth as outlined in Section 2 of Republic Act No. 1379.
Legal Arguments by Petitioners
The petitioners' motion for reconsideration rests on two main arguments: first, they assert that the Sandiganbayan erred in granting the Motion for Partial Summary Judgment due to the Republic's prior intention to file a separate forfeiture action concerning Arelma's assets, and second, they claim the Sandiganbayan lacked jurisdiction over the Arelma assets, as they are held in the United States by Merrill Lynch.
Court's Response to Jurisdiction Claims
The Supreme Court, upon reviewing the Office of the Solicitor General's opposition filed on August 16, 2012, determined that the petitioners' concerns regarding jurisdiction were repetitive of previous arguments already addressed in the April 25, 2012 decision. The Court clarified that the forfeiture petition included Arelma, Inc., demonstrating that it was indeed part of the overall forfeiture effort and thus under the Sandiganbayan's jurisdiction.
Distinction of Judgment Matters
The Court emphasized that the ruling in the Swiss Deposits case (G.R. No. 152154) only pertained to specific Swiss accounts and did not prevent separate judgments regarding other listed assets subjected to forfeiture in Civil Case No. 0141. Upholding the principle that multiple judgments can exist within separate claims in an action, it affirmed the validity of the Sandiganbayan's rulings on different asset categories.
Addressing the Petitioners' Further Claims
The petitioners further contended that the Sandiganbayan's authority was limited since they had reserved the right to initiate a distinct forfeiture action for the Arelma account. The Court found no substantiation for this claim and reiterated that the law does not impose limitations based on self-imposed statements by one party in such proceedings.
Framework of Execution and Jurisdiction
The Court distinguished the concepts of judgment issuance and execution, asserting that jurisdiction granted to the Sandiganbayan to determine asset character does not hinge on territorial ownership for enforcement purposes. The execution of a judgment is regarded as a ministerial act separate from its judicial declarations.
Principles of Forfeiture and Jurisdiction Over Res
The Court underscored that forfeiture proceedings are primarily actions in rem or quasi in rem, granting jurisdiction through either legal process seizure or recognition in legal proceedings. The principle of potential jurisdiction was explained, reinforcing that mere possession of the subject property is not a requisite for the court's power over the res.
International Comity Considerations
In referencing a decision fro
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Case Overview
- Parties Involved:
- Petitioner: Ferdinand R. Marcos, Jr.
- Respondent: Republic of the Philippines, represented by the Presidential Commission on Good Government.
- Case Numbers: G.R. No. 189434 and G.R. No. 189505
- Date of Decision: March 12, 2014
- Prior Decision: The case follows a Decision rendered on April 25, 2012, affirming the Sandiganbayan’s decision of April 2, 2009.
Background of the Case
- The case centers on the assets of Arelma, S.A., an entity created by the late Ferdinand E. Marcos, which were declared forfeited in favor of the Republic of the Philippines.
- The Sandiganbayan identified the assets acquired by the Marcoses as grossly disproportionate to their salaries as public officials, leading to the presumption of ill-gotten wealth under Republic Act No. 1379.
Petitioners' Arguments
- Petitioners argue that:
- The Sandiganbayan erred in granting a Motion for Partial Summary Judgment, claiming that the Republic had stated it would file a separate forfeiture action concerning Arelma's assets.
- Civil Case No. 0141 had already concluded, which should prevent further claims on the same matter.
- The Sandiganbayan lacked territorial jurisdiction over