G.R. No. 211098, April 20, 2016
THE WELLEX GROUP, INC., Petitioner, vs. SHERIFF EDGARDO A. URIETA OF THE SANDIGANBAYAN SECURITY AND SHERIFF SERVICES, THE SANDIGANBAYAN SECURITY AND SHERIFF SERVICES, AND BDO UNIBANK, INC. (FORMERLY EQUITABLE PCI BANK, INC.), Respondents.

FACTS

Petitioner Wellex Group, Inc. obtained a ₱500,000,000 loan from Equitable-PCI Bank, secured by a chattel mortgage over 450,000,000 Waterfront Philippines, Inc. shares. The loan was funded from an Investment Management Agreement (IMA) Account No. 101-78056-1 under the name “Jose Velarde,” which was later adjudged by the Sandiganbayan to be owned by former President Joseph Estrada as part of his ill-gotten wealth from plunder. In its 2007 Decision convicting Estrada of plunder, the Sandiganbayan ordered the forfeiture in favor of the government of the ₱189,000,000 deposited in the Jose Velarde account, inclusive of interests and income. After Estrada’s pardon (which excluded forfeitures), the Sandiganbayan issued an Amended Writ of Execution on February 19, 2008, specifically including the Waterfront shares as forfeited property. Wellex Group claimed it had extinguished the loan by paying directly to the owner of the IMA account (Jose Velarde/Estrada) and sought to recover the shares. It filed a Complaint for recovery of possession before the Regional Trial Court (RTC) of Makati, which dismissed the case for lack of cause of action. Wellex Group elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether a third-party claim involving properties forfeited due to a plunder conviction should be filed before the Sandiganbayan or in a separate civil action.

RULING

In his dissenting opinion, Justice Leonen held that third-party claims involving properties forfeited as a consequence of a plunder conviction must be filed before the Sandiganbayan, regardless of the civil nature of such claims. The Sandiganbayan retains jurisdiction over all incidents relating to the forfeiture of ill-gotten wealth, including third-party claims, as part of its execution of a final judgment. The Amended Writ of Execution explicitly included the Waterfront shares as forfeited assets traceable to the Velarde account. Thus, Wellex Group’s claim of ownership or lien over the shares should have been asserted in the Sandiganbayan proceeding, not in a separate civil action before the RTC. The dismissal by the RTC was proper, as the Sandiganbayan has exclusive jurisdiction to resolve disputes over forfeited properties arising from its plunder judgment.