G.R. No. 174431; August 6, 2012
The Heirs of Jolly R. Bugarin, namely Ma. Aileen H. Bugarin, Ma. Linda B. Abiog and Ma. Annette B. Sumulong, Petitioners, vs. Republic of the Philippines, Respondent.

FACTS

The case originated from a petition for forfeiture filed by the Presidential Commission on Good Government (PCGG) against the late NBI Director Jolly R. Bugarin under Republic Act No. 1379. The Sandiganbayan initially dismissed the petition in 1991. However, the Supreme Court, in its January 30, 2002 Decision in Republic v. Sandiganbayan, reversed this dismissal. The High Court meticulously examined the evidence, including Bugarin’s own summary of property acquisitions, and found that from 1968 to 1980, he had amassed wealth totaling ₱2,170,163.00 against a lawful income of only ₱766,548.00. The Court thus ordered the forfeiture of properties disproportionate to his lawful income and remanded the case to the Sandiganbayan for the specific determination of which properties to forfeit. This 2002 Decision became final and executory on June 25, 2004.
Upon remand, the Sandiganbayan set hearings to identify the specific properties. The PCGG submitted a list. The heirs of Bugarin, however, filed various motions, including a motion to dismiss and a motion for leave to file a motion to dismiss, which the Sandiganbayan denied, noting the finality of the Supreme Court’s forfeiture order. Ultimately, in a hearing where only the heirs’ counsel appeared, the Sandiganbayan deemed the case submitted for resolution and subsequently issued the assailed April 3, 2006 Resolution, which ordered the forfeiture of specific properties listed by the PCGG, valued at ₱1,697,333.00.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in issuing its April 3, 2006 Resolution ordering the forfeiture of specific properties without conducting a full-blown trial or further hearings as allegedly mandated by the Supreme Court’s remand order.

RULING

The Supreme Court denied the petition and affirmed the Sandiganbayan’s resolutions. The Court held that no grave abuse of discretion attended the Sandiganbayan’s actions. The legal logic is clear: the Supreme Court’s 2002 Decision had already made a final and conclusive finding that Bugarin unlawfully acquired assets disproportionate to his lawful income during the specified period. The remand to the Sandiganbayan was solely for the ministerial and executory task of identifying and listing the specific properties that corresponded to the illegally acquired wealth, the total value of which had already been judicially established. The purpose of the remand was not to re-litigate the issue of unlawful acquisition, which was already settled with finality.
The Sandiganbayan complied with this directive by considering the PCGG’s submitted list, which was based on the very evidence already scrutinized and accepted by the Supreme Court. The heirs’ persistent filing of prohibited pleadings and motions to dismiss, all seeking to re-open the final forfeiture judgment, constituted mere dilatory tactics. The Sandiganbayan correctly denied these motions and proceeded to resolve the matter based on the available records. A full-blown trial was unnecessary as there were no more factual issues to try regarding the illegality of the acquisitions. The Sandiganbayan’s act of implementing the final forfeiture order by identifying the properties from the established record was a proper exercise of its executionary jurisdiction and not a capricious or whimsical act amounting to grave abuse of discretion.