G.R. No. 148154. December 17, 2007.
Republic of the Philippines, represented by the Presidential Commission on Good Government (PCGG), petitioner, vs. Sandiganbayan (Second Division) and Ferdinand R. Marcos, Jr. (as executor of the estate of Ferdinand E. Marcos), respondents.

FACTS

The PCGG filed a complaint to recover alleged ill-gotten wealth from former President Ferdinand E. Marcos, his family, and alleged crony Roman A. Cruz, Jr. The Marcoses were declared in default in 1989 for failure to file an answer. After the former President’s death, his estate was substituted. In 1992, the Sandiganbayan lifted the default order as to Imelda Marcos. In 1999, the court granted a motion by respondent Ferdinand “Bongbong” Marcos, Jr., as executor of his father’s estate, for leave to file a responsive pleading, despite the estate’s technical default status. Instead of filing an answer, respondent filed a Motion for a Bill of Particulars, seeking clearer statements on the allegations. The Sandiganbayan granted this motion. The PCGG filed this certiorari petition, arguing the grant was improper.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in granting the Motion for a Bill of Particulars filed by the estate of a defendant who was in default.

RULING

No, the Sandiganbayan did not commit grave abuse of discretion. The Supreme Court upheld the Sandiganbayan’s resolutions. The legal logic proceeds from the court’s discretionary power to set aside an order of default under Rule 9, Section 3(b) of the Rules of Court. While the estate of the deceased President remained in default, the Sandiganbayan’s prior act of granting leave to file a responsive pleading was a discretionary relief from the default order. This allowed the executor to participate in the proceedings. Once granted that relief, the respondent stood as a party who could file appropriate motions, including one for a bill of particulars. A bill of particulars is a remedy to clarify vague allegations in a pleading so a defendant can properly prepare a responsive pleading. The PCGG’s complaint, spanning two decades of alleged accumulation of wealth, was inherently complex. The Sandiganbayan, in the interest of justice and to ensure a fair trial on the merits, acted within its sound discretion in requiring the PCGG to provide more specific details. The Court found no capricious or whimsical exercise of judgment amounting to grave abuse of discretion, as the anti-graft court’s actions were aimed at clarifying the issues for a more orderly and informed trial.