G.R. No. 152154 - Republic vs. Sandiganbayan

On December 17, 1991, the Republic of the Philippines, through the Presidential Commission on Good Government (PCGG), filed a petition for forfeiture against Ferdinand E. Marcos and Imelda R. Marcos, seeking to declare US$356 million held in escrow as ill-gotten wealth.
The funds were previously held in various Swiss bank accounts under different foundations.
The petition also sought the forfeiture of US$25 million and US$5 million in treasury notes, which exceeded the Marcos couple's lawful income.
Respondents filed their answer on October 18, 1993, and a General Agreement for a global settlement was executed on December 28, 1993.
The Sandiganbayan conducted hearings and denied the motion for summary judgment on November 20, 1997, stating that the motion to approve the compromise agreement took precedence.

On March 10, 2000, the Republic filed a motion for summary judgment, asserting that the respondents admitted essential facts warranting forfeiture.
The Sandiganbayan granted the motion on September 19, 2000, declaring the Swiss deposits as unlawfully acquired wealth.
Respondents filed motions for reconsideration, which were subsequently denied by the Sandiganbayan on January 31, 2002, reversing its earlier decision.

The Republic filed a petition for certiorari under Rule 65, arguing that the Sandiganbayan committed grave abuse of discretion in reversing its decision.
The Republic contended that it had proven its case for forfeiture under RA 1379, citing admissions made by the respondents regarding their public office and the ill-gotten nature of the funds.

Respondents argued that the Republic had a plain, speedy, and adequate remedy at the Sandiganbayan and that the court did not abuse its discretion in setting the case for further proceedings.
They claimed that the motion for summary judgment was barred by laches and that the Republic failed to establish a prima facie case for forfeiture.

The Court acknowledged that certiorari is generally not the proper remedy for reviewing decisions of the Sandiganbayan but allowed it due to the case's public interest and historical significance.
The Court emphasized the need for a prompt resolution of cases involving ill-gotten wealth.

The Court found that the respondents failed to raise genuine issues of fact in their pleadings, justifying the summary judgment.
The Court noted that the respondents' defenses were insufficient and lacked substance.

The Court held that the Republic established a prima facie case for forfeiture under RA 1379, demonstrating that the assets were unlawfully acquired.
The Court found that the total amount of the Swiss deposits was grossly disproportionate to the lawful income of the Marcoses.

The Court ruled that the respondents made judicial admissions regarding their ownership of the Swiss funds, which were binding and could not be contradicted.
The admissions were derived from various pleadings and documents submitted by the respondents.

The Court determined that the failure to implead the foreign foundations was not fatal to the case, as the foundations were not indispensable parties.
The Court noted that the absence of the foundations did not prevent a complete determination of the issues.