G.R. No. 189590, APRIL 23, 2018
REPUBLIC OF THE PHILIPPINES, Petitioner, vs. HON. SANDIGANBAYAN, ROMEO G. PANGANIBAN, FE L. PANGANIBAN, GERALDINE L. PANGANIBAN, ELSA P. DE LUNA AND PURITA P. SARMIENTO, Respondents.

FACTS

The Republic, through the Office of the Ombudsman, filed a petition for forfeiture under Republic Act No. 1379 against Romeo Panganiban, a former DPWH Regional Director, and his family members. The petition sought to forfeit five real properties valued at approximately ₱40.7 million, alleging they were unlawfully acquired. The Republic’s case hinged on a purported manifest disproportion between these assets and Romeo’s legitimate income, calculated from his 1986 to 2001 SALNs and service record, showing a net worth increase to ₱13.2 million against a total salary of only ₱2.5 million. The other respondents were impleaded on the premise they held the properties for Romeo.
After the Republic presented its evidence, the respondents filed a Demurrer to Evidence. The Sandiganbayan partially granted it, dismissing the case as to the properties registered in the names of Romeo’s sisters, Elsa and Purita (the Ayala Alabang and Callos-Sta. Cruz properties), and his daughter Geraldine (co-owner of the Los Angeles property). The anti-graft court ruled the Republic failed to prove these properties were held in trust for Romeo, as the evidence did not overcome the presumption of the sisters’ and daughter’s ownership under the Torrens titles.

ISSUE

Whether the Sandiganbayan acted with grave abuse of discretion in partially granting the Demurrer to Evidence by dismissing the forfeiture case against the properties registered in the names of Romeo Panganiban’s sisters and daughter.

RULING

No, the Sandiganbayan did not commit grave abuse of discretion. A demurrer tests the sufficiency of the plaintiff’s evidence. In granting it, the court determines that upon the facts and the law, the plaintiff has shown no right to relief. The Supreme Court found that the Sandiganbayan’s assessment was based on a correct application of this standard. The Republic’s evidence for forfeiture against the sister- and daughter-owned properties was purely circumstantial, relying on Romeo’s salary discrepancy and the familial relationships. Crucially, it failed to present clear and convincing evidence to pierce the Torrens titles and prove that the registered owners were mere nominal holders or that the properties were actually funded by Romeo. The Sandiganbayan correctly held that ownership is prima facie evidenced by the certificate of title, and the Republic did not substantiate its allegation of a trust relationship. Therefore, its ruling was a valid exercise of judicial discretion, not a capricious or whimsical act amounting to grave abuse of discretion. The petition for certiorari was denied.