G.R. No. 195837 - Republic vs. Lucio Tan, Estate of Ferdid E. Marcos, et al.

The Republic bears the burden of proving its claims with admissible and relevant evidence.
Sandiganbayan and the Supreme Court must carefully separate substantiated evidence from unproven claims.
Avoidance of re-litigation of already decided issues emphasized.

Complaint and Second Amended Complaint filed; several motions and additional parties introduced.
Trial commenced in 2006 after years of delays.
Issues arose on the presentation and admissibility of evidence and witnesses.
Motions to dismiss (demurrer to evidence) granted as to some respondents.
Various petitions filed assailing different Sandiganbayan resolutions and orders.

Acquisition of General Bank and Trust Company (GenBank) assets via Allied Banking Corp. without sufficient collateral.
Transfer of substantial beneficial interests in Asia Brewery to Marcos and associates.
Provision of gifts, bribes, and dividends to Marcos family in support of business ventures.
Establishment of Shareholdings, Inc. to disguise ownership of multiple corporations.
Sale of Development Bank’s controlling interest in Century Park Sheraton Hotel to undercapitalized company linked to Tan.
Illegal use of tax stamps and importation violations in tobacco-related companies.

Testimony of Joselito and Aderito Yujuico disallowed based on res judicata due to prior cases on GenBank liquidation.
Imelda Marcos’ Amended Answer with Counterclaim not initially admitted; later offered but considered hearsay regarding other respondents.
Written Disclosure of Lucio Tan and affidavit of Rolando Gapud largely deemed inadmissible due to lack of direct testimony.
Testimony of Ferdinand Marcos Jr. considered hearsay but admissible as evidence of statements having been made (independently relevant).
Many documentary exhibits found insufficiently authenticated, mostly photocopies or private documents lacking proper foundation.

Previous Supreme Court rulling in Republic v. Desierto on the legality and good faith of the Sipalay Deal barred re-litigation of bad faith of Development Bank officers.
The principle of res judicata by conclusiveness of judgment applied to the bad faith issue in connection with respondents Ferry and Zalamea.
However, decisions reached in preliminary investigations or by administrative bodies do not have res judicata effect in judicial proceedings.

The Republic did not commit forum shopping since all related petitions originated from the same case.
Different issues raised in various petitions, no repeated suits in different courts.

Ill-gotten wealth includes assets obtained by improper or illegal use of government funds or by taking undue advantage of office, authority, influence, connections, or relationships for personal gain.
Can include private assets acquired through undue advantage.
Must be proven by preponderance of evidence.
Legal and doctrinal bases include EO Nos. 1, 2, 14, and the PCGG Rules and Regulations.

Republic failed to prove required elements by preponderance:
- Evidence lacked adequate proof on how assets were acquired by taking improper advantage.
- Many documents inadmissible for lack of proper authentication or being hearsay.
- Key statements of Imelda Marcos, Gapud’s affidavit, and Tan’s written disclosure lacked probative value.
Republic established the existence of undue benefit only in the grant of Asia Brewery’s license due to Tan’s relationship with Marcos.
Total amount of ill-gotten wealth from Asia Brewery license not established; remand for further evidence and assessment suggested.

Sandiganbayan’s resolutions on demurrers to evidence properly constituted judgments on merits, not mere minute resolutions.
Motions to di

The case involves consolidated petitions recognizing the Republic of the Philippines (Republic), through the Presidential Commission on Good Government (PCGG), as petitioner.
Respondents include Lucio C. Tan (Tan), Estate of former President Ferdinand E. Marcos (Marcos), Imelda R. Marcos (Imelda), their heirs, subordinates, close relatives, business associates, and several corporations alleged to have been involved in the concealment and control of allegedly ill-gotten wealth.
The case originates from a Complaint filed on July 17, 1987, seeking recovery and reconveyance of ill-gotten wealth allegedly acquired through scheming and undue influence during the Marcos administration.

The Complaint detailed the liquidation of GenBank and acquisition of its assets by Tan through Allied Banking Corporation (Allied Bank) without sufficient collateral or consideration.
It alleged Tan's delivery of substantial beneficial interest in shares of stock in Asia Brewery Inc. (Asia Brewery) to Marcos and Imelda in exchange for preferential privileges.
The establishment of Shareholdings, Inc. to control numerous companies allegedly acting as dummies to conceal ill-gotten wealth.
Several motions and amended complaints were filed between 1991 and 2006, involving corporations, heirs, and individuals linked to the Marcoses and Tan.
There were multiple delays in evidence presentation; the Sandiganbayan limited the Republic's presentation and excluded key testimonies, leading to multiple questions on propriety of trial and inhibitions motions.

Whether certain respondents impliedly admitted allegations by filing a demurrer to evidence.
Applicability of res judicata principles, especially regarding prior cases like Republic v. Desierto and the General Bank & Trust Co. v. Central Bank of the Philippines (GenBank Liquidation Case).
Validity of Sandiganbayan's dismissals, rulings on evidence exclusion, and internal procedural rules, including procedural resolutions vs. decisions.
Whether the concept of ill-gotten wealth should be strictly confined to assets originating from government funds or includes those acquired by undue advantage of office, influence, or relationships.
Whether the Republic's evidence quantitatively and qualitatively sufficiently proved the acquisition of ill-gotten wealth.
Whether Philip Morris Fortune Tobacco Corp. (PMFTC, Inc.) is an indispensable party in relation to alleged fraudulent transfer of assets from Fortune Tobacco and Northern Tobacco.

Ill-Gotten Wealth: Defined broadly under Executive Orders Nos. 1 and 2 and PCGG Rules, as properties acquired (a) through improper or illegal use of government funds or (b) through taking undue advantage of position or influence resulting in unjust enrichment and grave prejudice to the Republic.
Res Judicata: Bar by prior judgment and conclusiveness of judgment prevent re-litigation of finally adjudicated matters between same or substantially identical parties.
Evidence Rules: Em