ESTATE OF FERDINAND E. MARCOS v. REPUBLIC

Estate of Ferdinand E. Marcos v. Republic of the Philippines/Imelda Romuladez Marcos and Irene Marcos Araneta Vs. Republic of the Philippines

G.R. No. 213027/G.R. No. 213253

January 18, 2017

FACTS:

The present consolidated petitions emanated from the same Civil Case No. 0141, when the Republic filed a Motion for Partial Summary Judgment dated 24 June 2009 with respect to another property listed in the 1991 Petition. The Republic asked the Sandiganbayan to render judgment declaring the pieces of jewelry, known as the Malacanang Collection and specifically mentioned under paragraph 9 (6) of the 1991 Petition, as ill-gotten; and to subsequently cause this collection of jewelry to be declared forfeited in favor of the Republic.

In support of the motion, the Republic cited the letter dated 25 May 2009 sent to the PCGG by Imelda Marcos, through counsel, demanding "the immediate return of all her pieces of jewelry (i) taken by PCGG from Malacanang Palace and (ii) those turned over to PCGG by the U.S. Government." The Republic argued that the letter proved the claim of the Marcoses that they owned the Malacanang Collection, including the Hawaii Collection. It contended that "the lawful income of the Marcoses during their incumbencies as public officials was grossly disproportionate to the value of the pieces of jewelry."

Imelda Marcos and Irene Marcos Araneta stated that the Republic's Motion for Partial Summary Judgment was filed to justify the possession by the PCGG of the pieces of jewelry, even if these were not part of the forfeiture case -Civil Case No. 0141.

Imelda Marcos and Irene Marcos Araneta subsequently filed a Manifestation and Motion to Expunge dated 25 July 2009. In their Manifestation and Motion to Expunge, Imelda Marcos and Irene Marcos Araneta claimed that the filing of the Request for Admission was to an abdication of the earlier position of the Republic that the case was ripe for summary judgment. They argued that the Request for Admission entertained a possibly genuine issue as to a material fact, which was needed for the grant of the motion for summary judgment.

The Republic filed its Opposition dated 24 August 2009, in which it said that the Manifestation and Motion to Expunge of Imelda Marcos and Irene Marcos Araneta argued on trivial matters, raised puerile arguments, and failed to refute the contention that the collection was ill-gotten and subject to forfeiture. The Republic claimed that by operation of law, the failure of the Marcoses to respond resulted in their admission of the matters contained in the request.

In a Resolution dated 2 August 2010, the Sandiganbayan denied the Marcoses' Manifestation and Preliminary Comments and Manifestation and Motion to Expunge. After the submission of the parties of their respective memoranda, the Sandiganbayan issued a Partial Summary Judgment dated 13 January 2014 ruling that (1) the Malacanang Collection was part and subject of the forfeiture petition; (2) the Motion for Summary Judgment was proper; and (3) the forfeiture of the Malacanang Collection was justified pursuant to R.A. 1379.

In a Resolution dated 11 June 2014, the Sandiganbayan denied the Motions for Reconsideration for being mere rehashes of the arguments of the Marcoses in their Comments and Opposition to the Republic's Motion for Summary Judgment.

ISSUE:

Whether or not the Malacanang Collection can be subject of the forfeiture case.

HELD:

Yes. The Malacanang Collection is subject to forfeiture.

The Court stated that “whenever any public officer or employee has acquired during his incumbency an amount of property which is manifestly out of proportion to his salary as such public officer or employee and to his other lawful income and the income from legitimately acquired property, said property shall be presumed prima facie to have been unlawfully acquired."

In the present case, petitioners failed to satisfactorily show that the properties were lawfully acquired; hence, the prima facie presumption that they were unlawfully acquired prevails.