G.R. No. 212330 & 212612, November 14, 2023
ESTATE OF FERDINAND E. MARCOS, PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, ET AL., RESPONDENTS.

FACTS

The consolidated cases involve a 1978 Lease Contract over a 576,787-square meter parcel of land in Paoay, Ilocos Norte, between then-President Ferdinand E. Marcos, Sr., as lessor, and the Philippine Tourism Authority (PTA), as lessee. The contract had a 25-year term at a nominal rental of one peso per year, with the PTA undertaking to construct improvements, which included the “Malacañang of the North” and a sports complex. Following the 1986 EDSA Revolution, the Presidential Commission on Good Government (PCGG) sequestered the property. After the lease expired in 2003, the Estate of Marcos filed an unlawful detainer case to recover possession. Concurrently, the Republic, through the PCGG, filed a case in the Sandiganbayan seeking a declaration of the lease contract’s nullity and the reversion of the property to the State, alleging it was part of the ill-gotten wealth of the Marcos family.

ISSUE

The primary issue is whether the Sandiganbayan has jurisdiction over the action for the declaration of nullity of the 1978 Lease Contract and the recovery of the subject property.

RULING

Yes, the Sandiganbayan has jurisdiction. The Supreme Court affirmed the Sandiganbayan’s decision declaring the 1978 Lease Contract void and ordering the reversion of the property to the State. The Court held that the Sandiganbayan’s original and exclusive jurisdiction, under Presidential Decree No. 1606, extends not only to the principal action for the recovery of ill-gotten wealth but also to all incidents arising from, incidental to, or related to such cases. The action to nullify the lease contract, which involves property alleged to be ill-gotten, is intrinsically related to the Republic’s recovery case and thus falls squarely within the Sandiganbayan’s jurisdiction. The Court further ruled that the property is owned by the State. The land is part of the Paoay Lake National Park, declared as such by Republic Act No. 5631 in 1969, prior to the lease. The Court found no evidence that Marcos, Sr. or his predecessors-in-interest possessed the land in the concept of an owner for the required period to acquire a vested right or imperfect title. The lease, executed by Marcos while President to a government entity he controlled, for a grossly inadequate consideration, was a clear abuse of right and power. Consequently, the unlawful detainer action filed by the Estate was correctly dismissed, as the Sandiganbayan, having validly acquired jurisdiction over the res, is the proper forum to resolve all issues regarding ownership and possession.