G.R. No. 195837 , October 3, 2023
Republic of the Philippines, Petitioner, vs. Sandiganbayan (5th Division), Lucio C. Tan, et al., Respondents.

FACTS

The Republic, through the Presidential Commission on Good Government (PCGG), filed a complaint for reversion, reconveyance, restitution, accounting, and damages against Lucio C. Tan, the Estate of Ferdinand Marcos, and numerous other individuals and corporations. The Republic alleged that the vast business empire of Lucio Tan was amassed through ill-gotten wealth, acquired in unlawful concert with former President Ferdinand Marcos. The Republic asserted that the corporate shares and assets of the respondent corporations were illegally obtained using government funds and resources, constituting properties unlawfully acquired under Executive Orders Nos. 1 and 2.
The Sandiganbayan dismissed the Republic’s complaint. It found that the Republic failed to present sufficient preponderant evidence to prove its allegations. The Republic’s evidence, which included purported deeds of assignment and stock certificates, was deemed inadmissible for being mere photocopies, not properly authenticated, and lacking in probative value. The Republic’s subsequent motions, including a motion to admit a third amended complaint and a motion for inhibition, were also denied by the Sandiganbayan. The Republic elevated the case to the Supreme Court via consolidated petitions for review on certiorari.

ISSUE

The core issue is whether the Sandiganbayan committed grave abuse of discretion in dismissing the Republic’s complaint for failure to prove by preponderance of evidence that the subject properties were ill-gotten wealth acquired in violation of Executive Orders Nos. 1 and 2.

RULING

The Supreme Court, in a Decision penned by Justice Zalameda, denied the petitions and affirmed the Sandiganbayan’s rulings. The Court held that the Sandiganbayan did not commit grave abuse of discretion. The legal logic rests on the fundamental principle that in civil cases, the burden of proof lies with the plaintiff, who must establish its case by a preponderance of evidence. The Republic, as the plaintiff, failed to discharge this burden.
The Court meticulously examined the Republic’s evidence and found it wanting. The purported deeds of assignment and stock certificates, central to the Republic’s claim of ownership being transferred to Marcos nominees, were unauthenticated photocopies. Under the Rules of Court, when the subject of inquiry is the contents of a document, no evidence is admissible other than the original document itself, except in specific instances. The Republic failed to justify the non-production of the originals and did not lay the proper foundation for the admission of secondary evidence. Consequently, these documents were correctly excluded for being hearsay and lacking in probative value. Without this crucial evidence, the Republic’s narrative of illicit acquisition remained unsubstantiated allegation. The Sandiganbayan’s assessment of the evidence’s insufficiency was a factual determination within its jurisdiction, not tainted by arbitrariness. The denial of the motions for amendment and inhibition were likewise upheld as within the Sandiganbayan’s sound discretion.