G.R. No. 171701 ; February 8, 2012
Republic of the Philippines vs. Ma. Imelda “Imee” R. Marcos-Manotoc, et al.

FACTS

This case originated from Civil Case No. 0002 filed by the Presidential Commission on Good Government (PCGG) before the Sandiganbayan to recover alleged ill-gotten wealth amassed by former President Ferdinand Marcos, his family, and associates. The Republic, through the PCGG, filed a series of amended complaints, ultimately alleging that respondents, the Marcos children and others, actively collaborated in unlawfully appropriating public funds and property. Specific allegations included the use of media networks for personal benefit, dollar salting through a corporation, and the illegal acquisition of a bus company. The Republic sought reversion, reconveyance, accounting, and damages.
The procedural history is protracted. The Sandiganbayan issued pre-trial orders and eventually resolutions that prompted the Republic’s petition. A critical point was the Sandiganbayan’s treatment of the Republic’s evidence and its orders regarding the framing of issues for trial. The Republic assailed these resolutions, arguing they effectively dismissed parts of its case without a full trial on the merits, particularly concerning the alleged ill-gotten wealth and the respondents’ liability as collaborators and dummies.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in issuing its resolutions, which allegedly dismissed significant portions of the Republic’s case without allowing a full-blown trial on the merits.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion by the Sandiganbayan. The Court emphasized that the Sandiganbayan, as a trial court, has broad discretion in the conduct of pre-trial, including defining and simplifying the issues to be tried. The resolutions in question were interlocutory orders aimed at streamlining the trial by identifying the factual and legal issues from the pleadings and evidence presented during pre-trial conferences. The Court held that the Sandiganbayan did not dismiss the case but was performing its duty to ensure an orderly and expeditious trial. The Republic’s remedy was not a special civil action for certiorari but to proceed to trial and present its evidence on the issues as defined. The Court found that the Sandiganbayan acted within its jurisdiction and did not act in a capricious or whimsical manner. The proper course for the Republic was to adhere to the pre-trial orders and prove its allegations during the trial proper.