G.R. No. 148154 - Republic vs. Sandiganbayan

Case Summary (G.R. No. 148154)

Background of the Case and Initial Proceedings

During President Corazon C. Aquino's administration, the PCGG filed a complaint against former President Ferdinand E. Marcos, Imelda Marcos, and alleged cronies including Roman A. Cruz, Jr. The complaint sought recovery of ill-gotten wealth amassed during the Marcos regime, alleging disproportionate acquisition of numerous properties domestically and abroad, and prayed for damages including P50 billion moral damages. Cruz, holding significant public and corporate positions, was accused of conspiring with the Marcoses to divert public assets. Cruz filed an omnibus motion to dismiss and for bill of particulars in 1987, which was denied since the expanded complaint sufficiently alleged causes of action. Alias summonses were served on the Marcoses in Hawaii, who failed to answer and were declared in default in 1989.

Default Status and Substitution by Marcos Estate

Former President Marcos died in exile in Hawaii in 1989. His estate, represented by Imelda Marcos and their children, was substituted as defendant following a PCGG motion. Imelda Marcos subsequently filed a motion to set aside the default order, which was granted by the anti-graft court in 1992 and affirmed by the Supreme Court in 1994 on grounds of excusable negligence and meritorious defense. Mrs. Marcos filed her answer in 1995 denying allegations and asserting due process violations.

Motion for Leave and Bill of Particulars Filed by Respondent

Respondent Ferdinand R. Marcos, Jr., as executor of the estate, sought leave to file a responsive pleading in 1999 despite the default status of his deceased father. The Sandiganbayan granted this motion, allowing him ten days to submit his answer. Respondent obtained extensions but instead filed a Motion for Bill of Particulars, requesting clearer allegations regarding his father's participation in the alleged ill-gotten wealth accumulation. The PCGG opposed, arguing that the motion was dilatory, raised evidentiary issues, and contravened the prior resolution allowing only a responsive pleading.

Sandiganbayan’s Rulings on Bill of Particulars

The Sandiganbayan granted the motion for a bill of particulars in a January 31, 2000 Resolution, ruling that allegations against former President Marcos were vague, general, and mere conclusions of law, which did not enable the defendant to prepare an intelligent answer. The court ordered the PCGG to amend specific paragraphs of the Expanded Complaint specifying the nature, manner, period, extent of Marcos's participation, and the amount of damages. A subsequent motion for reconsideration filed by petitioner was denied on March 27, 2001, with the court holding that the bill of particulars was proper and not dilatory at the pre-trial stage, consistent with Section 1, Rule 12 of the 1997 Rules of Civil Procedure.

Petitioner's Grounds for Annulment of Sandiganbayan Resolutions

The PCGG urged the Supreme Court to nullify the Resolutions on two main grounds:

The motion for bill of particulars contravened Section 3, Rule 9 of the Rules of Civil Procedure in relation to the default order still binding the deceased defendant; thus, the estate could not file such a motion without lifting the default status.
The motion was dilatory and without basis, given that the complaint sufficiently alleged facts, and that the respondent had the opportunity and time to file an answer.
They further argued that granting the motion unfairly forced premature disclosure of evidentiary matters and that the phrases used in the complaint, including “unlawful concert,” were properly used to allege conspiracy.

Respondent’s Arguments in Opposition

Respondent contended that the Supreme Court’s prior rulings required the PCGG to comply with motions for bills of particulars due to vagueness in complaints against the Marcoses. He argued that the May 28, 1999 Resolution granting leave to file a responsive pleading effectively lifted the default order, negating the PCGG’s argument. He refuted the claim of delay, asserting that the government's refusal to provide details caused procedural slowdowns. He emphasized that factual vagueness prevented the formulation of an intelligent answer.

Supreme Court’s Analysis on Default Order and Lifting thereof

The Court clarified that a default order precludes the defendant from participating in the trial without proper relief such as a motion to set aside the default. However, the granting by the Sandiganbayan of leave to file a responsive pleading, extensions, and a motion for bill of particulars is understood as implicitly lifting the default order, particularly where no judgment had been rendered and no motion for reconsideration of the leave order was filed. The Court referenced governing provisions and jurisprudence that allow courts broad discretion to set aside defaults, prioritizing substantive justice over mere technicalities.

Justification for Granting the Bill of Particulars

The Court recognized that the expanded complaint included detailed allegations against Cruz but only generally implicated Marcos without specifying ultimate facts demonstrating his participation or conspiracy. The Court cited prior cases applying the “Virata-Mapa Doctrine” which mandates a bill of particulars—not dismissal—as recourse for complaints unduly general or conclusory in ill-gotten wealth cases. This doctrine safeguards the right to due process by requiring particularity to enable in

Case Syllabus (G.R. No. 148154)

Facts and Background of the Case

The case arises from a protracted legal battle of over 20 years between the Philippine government and the Marcoses, involving allegations of ill-gotten wealth amassed during the 20-year presidency of Ferdinand E. Marcos.
The Presidential Commission on Good Government (PCGG), under President Corazon C. Aquino’s administration, filed suits against former President Marcos, former First Lady Imelda Marcos, Roman A. Cruz, Jr. (an alleged crony), and other purported dummies before the Sandiganbayan, the anti-graft court.
Roman A. Cruz, Jr. held significant government and corporate roles including president and general manager of the Government Service Insurance System (GSIS), president of Philippine Airlines (PAL), and chairman of Commercial Bank of Manila (CBM).
The PCGG’s complaint alleged that Cruz, in conspiracy with the Marcoses, engaged in acquiring assets disproportionate to Cruz’s legal income, such as residential lots, condominiums in the Philippines and USA, properties in California, and other assets.
The PCGG sought reconveyance, reversion, accounting, restitution, and damages totaling billions of pesos in moral and exemplary damages.
Cruz filed an omnibus motion to dismiss and for a bill of particulars; after several procedural developments and service of alias summonses issuing to the Marcoses in Hawaii, the Marcoses were declared in default for failure to file answers.
After former President Marcos’s death in 1989, his estate was substituted as a defendant, with Ferdinand R. Marcos, Jr. as executor.
Mrs. Marcos was allowed to file her answer after the default was set aside due to excusable neglect and meritorious defense.
Ferdinand R. Marcos, Jr. filed a motion for leave to file a responsive pleading and later a motion for a bill of particulars, which the PCGG opposed.
The Sandiganbayan granted the motion for bill of particulars and denied the government’s motion for reconsideration, prompting a petition for certiorari by the PCGG.

Issue before the Supreme Court

Whether the Sandiganbayan committed grave abuse of discretion amounting to lack or excess of jurisdiction when it granted the motion for a bill of particulars filed by the executor of the estate of a defaulting and deceased defendant.
Whether the motion for a bill of particulars acceded to after the default order was declared against former President Marcos was proper.
The propriety and legal effect of the court’s actions in allowing filings by the executor despite the absence of a formal lifting of the default order.

Legal Principles and Procedural Rules Applied

Under Philippine Rules of Court Rule 9, Section 3, a party declared in default is entitled to notice but cannot participate in the trial unless the default order is lifted.
Remedies against a default order include a motion to set aside the order due to fraud, accident, mistake, or excusable neglect with a showing of meritorious defense, among other procedural remedies.
A motion for a bill of particulars under Rule 12, Section 1, may be filed before filing a responsive pleading to clarify vague or general allegations to enable intelligent defense, particularly at the pre-trial stage.
The Court takes a liberal approach in setting aside default orders to ensure substantive justice and due process, especially where no real injury results and where litigants merely seek to prepare intelligent pleadings.
The “Virata-Mapa Doctrine” establishes that for complaints related to ill