G.R. No. 115748 August 7, 1996
Republic of the Philippines (represented by the PCGG), petitioner, vs. Sandiganbayan (Second Division) and Lucio C. Tan, et al., respondents.

FACTS

The Presidential Commission on Good Government (PCGG) filed a complaint for reconveyance, reversion, accounting, and damages against Lucio Tan, Ferdinand Marcos, and others. The PCGG later filed a Second Amended Complaint, impleading additional individuals and corporations and revising its allegations. Several corporate defendants filed a Motion for a More Definite Statement or a Bill of Particulars, arguing that the amended complaint’s allegations were vague. They sought specifics on how defendants beneficially owned or controlled listed corporations, the nature of support provided by the Marcos spouses, which alleged illegal acts were imputed to corporate defendants, which acts were committed singly or collectively, and the details of claimed actual damages.
The PCGG opposed, contending the allegations were sufficient and that the requested particulars pertained to evidentiary matters. The Sandiganbayan granted the motion, ruling the complaint articulated conclusions of law unsupported by factual premises, making it inadequate for defendants to comprehend their liability. The PCGG’s motion for reconsideration was denied, prompting this petition alleging grave abuse of discretion by the Sandiganbayan.

ISSUE

Whether the Sandiganbayan acted with grave abuse of discretion in granting the motion for a bill of particulars.

RULING

The Supreme Court dismissed the petition and affirmed the Sandiganbayan’s resolutions, subject to modifications. The Court held that the Sandiganbayan did not commit grave abuse of discretion. The function of a bill of particulars is to clarify vague pleadings, enabling a party to prepare an intelligent answer, meet the issues squarely, and avoid surprise at trial. This is crucial because defenses not pleaded in the answer are generally deemed waived.
The Court agreed that paragraphs 6-a and 14-c of the amended complaint required clarification. The allegations on beneficial ownership and control, as well as the nature of the Marcoses’ support, were insufficiently detailed, being mere conclusions of law. Defendants were entitled to know the specific manner of ownership (e.g., shareholdings, voting trusts) and the particulars of the alleged support to properly frame their defenses.
However, the Court modified the Sandiganbayan’s order regarding paragraphs 16-20 (the causes of action) and the request to specify acts committed singly or collectively. The PCGG admitted the acts in those causes of action pertained to individual defendants, making further specification unnecessary. Furthermore, the “Specific Averments of Defendants’ Illegal Acts” in the complaint already detailed the alleged collective and individual acts, providing adequate information. Thus, the grant of the bill of particulars was proper for the deficient allegations but not for those already sufficiently detailed.