G.R. No. 165835 ; June 22, 2005
MAJOR GENERAL CARLOS F. GARCIA, Petitioner, vs. SANDIGANBAYAN and the OFFICE OF THE OMBUDSMAN, Respondents.

FACTS

Petitioner Major General Carlos F. Garcia, then Deputy Chief of Staff for Comptrollership of the AFP, was the subject of a forfeiture proceeding under Republic Act No. 1379 (An Act Forfeiting Unlawfully Acquired Property) filed by the Republic, through the Office of the Ombudsman, before the Sandiganbayan. The petition alleged that Garcia acquired properties manifestly disproportionate to his lawful income. The Sandiganbayan granted the Republic’s ex parte application and issued a writ of preliminary attachment. Garcia filed a Motion to Dismiss and the instant Petition for Certiorari, challenging the Sandiganbayan’s jurisdiction.
Garcia argued that the Sandiganbayan, principally a criminal court, lacks jurisdiction over separate civil actions for forfeiture under R.A. No. 1379 , asserting that such jurisdiction resides exclusively with the Regional Trial Courts pursuant to Section 2 of the law. He theorized that amendments to Presidential Decree No. 1606 via Executive Orders Nos. 14 and 14-A vested the Sandiganbayan with jurisdiction only over similar civil actions involving the ill-gotten wealth of former President Ferdinand Marcos, his family, and cronies, and not over cases against other public officers like himself.

ISSUE

Whether the Sandiganbayan has jurisdiction over a petition for forfeiture of unlawfully acquired property under R.A. No. 1379 filed against a public officer other than former President Marcos, his family, or cronies.

RULING

Yes. The Sandiganbayan correctly exercised jurisdiction. The Court clarified that a forfeiture proceeding under R.A. No. 1379 is an action in rem, quasi-criminal in nature, and is a special civil action. The jurisdiction of the Sandiganbayan is determined by the nature of the offense and the salary grade of the accused public officer, as provided in Presidential Decree No. 1606, as amended. Section 4 of P.D. No. 1606 explicitly grants the Sandiganbayan exclusive original jurisdiction over “civil and criminal cases filed pursuant to and in connection with Executive Order Nos. 1, 2, 14 and 14-A,” issued in 1986. Crucially, Executive Order No. 14, Section 1 states that such civil suits for recovery of ill-gotten wealth “may be filed independently of any criminal proceedings and shall be governed by the Rules of Court.” The Court held that this provision is not limited to cases against the Marcoses but applies to all actions for the recovery of ill-gotten wealth, thereby vesting the Sandiganbayan with jurisdiction over the forfeiture case against Garcia. The amendments integrated R.A. No. 1379 proceedings into the Sandiganbayan’s jurisdiction for all public officers within its authority, not just a specific class of individuals.