G.R. No. 152154. July 15, 2003.
Republic of the Philippines, petitioner, vs. Honorable Sandiganbayan (Special First Division), Ferdinand E. Marcos (Represented by his Estate/Heirs) and Imelda Romualdez Marcos, respondents.

FACTS

The Republic, through the PCGG, filed a petition for forfeiture under R.A. 1379 against the Marcos estate and Imelda Marcos, seeking to declare as ill-gotten wealth approximately US$356 million (later over US$658 million with interest) held in Swiss foundations and subsequently transferred to an escrow account at the Philippine National Bank. The Swiss Federal Supreme Court had previously ruled the funds were of illegal provenance, ordering their transfer to the Philippines pending final forfeiture proceedings. The Sandiganbayan initially granted the Republic’s motion for summary judgment and ordered the funds forfeited on September 19, 2000. However, upon a motion for reconsideration filed by the Marcos heirs, the Sandiganbayan reversed itself in a Resolution dated January 31, 2002, setting aside the forfeiture. The court held that a full trial was necessary because the Swiss court’s decision was not yet final and executory, and because Imelda Marcos claimed sole beneficial ownership of 90% of the funds, introducing a genuine factual issue regarding ownership.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in setting aside its summary judgment and ordering a full trial on the merits.

RULING

Yes, the Supreme Court granted the petition and reinstated the forfeiture. The legal logic is clear: summary judgment is proper when there is no genuine issue as to any material fact. The respondents, through their pleadings and judicial admissions, had effectively conceded the factual premises for forfeiture. They admitted they had no lawful ownership over the funds and did not present evidence of legitimate acquisition. The claim of Imelda Marcos of 90% beneficial ownership, raised belatedly, was a sham and self-serving assertion designed to create a fictitious factual issue. It was inconsistent with their prior judicial admissions and the established fact that the funds were hidden using dummy foundations. The Swiss court’s final judgments, which found the funds to be of illegal origin, provided a sufficient factual basis. The purpose of R.A. 1379 is forfeiture of unlawfully acquired property, not determination of precise ownership among claimants. Since the essential fact—that the assets were unlawfully acquired and grossly disproportionate to the Marcoses’ lawful income—was established and uncontroverted, no trial was needed. The Sandiganbayan’s disregard of these judicial admissions and its order for a full trial constituted a capricious and whimsical exercise of judgment, amounting to grave abuse of discretion.