G.R. No. 214071. February 15, 2022.
REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE ANTI-MONEY LAUNDERING COUNCIL, PETITIONER, VS. HON. ANTONIO M. EUGENIO, JR., AS THE FORMER PRESIDING JUDGE OF BRANCH 24, REGIONAL TRIAL COURT, CITY OF MANILA; HON. LYLIHA L. ABELLA-AQUINO, AS ACTING PRESIDING JUDGE OF BRANCH 24, REGIONAL TRIAL COURT, CITY OF MANILA; THE ESTATE OF TERESITA ROJO CORPUS; AND TERESITA GOMEZ, RESPONDENTS.

FACTS

This case originated from Civil Case No. 03-107324, a civil forfeiture (money laundering) case filed by the Republic, through the Anti-Money Laundering Council (AMLC), against Conrado Ariola, Jr. and his conspirators before the RTC of Manila. The AMLC sought the forfeiture of assets related to a fraudulent investment scheme operated through Five Vision Consultancy, Inc. Respondents Teresita Corpus and Teresita Gomez testified for the AMLC during the forfeiture proceedings, stating they were induced to invest substantial sums in Five Vision. The RTC-Makati, in a separate collection case, found Corpus invested P4,720,000.00 and Gomez invested P11,799,000.00. On January 11, 2011, the RTC-Manila granted the forfeiture petition, declaring the bank accounts forfeited in favor of the government.
On February 8, 2011, Corpus and Gomez filed a “Second Verified Petition” under Section 35 of the Rules on Civil Forfeiture (A.M. No. 05-11-04-SC), claiming a legitimate interest in the forfeited funds equivalent to their investments and praying to litigate as pauper litigants. The RTC-Manila, on February 18, 2011, ordered the AMLC to comment within 15 days. The AMLC filed a Manifestation and Motion arguing its deadline to comment should be suspended until the court ruled on the petition’s sufficiency in form and substance and the pauper litigant motion. The RTC-Manila set the pauper motion for hearing and later, on May 23, 2011, granted it, exempting respondents from fees.
On September 21, 2011, respondents moved for approval of their claim, arguing it was uncontested as the AMLC had not filed a comment and had used their testimonies as evidence. The AMLC opposed, reiterating its position that its time to comment should start only after a finding of sufficiency. The RTC-Manila, in an Order dated January 31, 2012, granted respondents’ motion. It noted the AMLC had been ordered to comment on an earlier “Verified Petition” in 2006 and on this Second Verified Petition, thus having two opportunities to oppose. It ruled that Section 37 of the Rules does not require a separate order declaring sufficiency before directing a comment, and found it unfair for the AMLC to contest claims after using respondents’ testimonies. The order was later corrected on August 17, 2012, to specify the award amounts. The AMLC’s motion for reconsideration was denied.
The AMLC filed a Petition for Certiorari with the CA, which was dismissed in a Decision dated January 27, 2014. The CA held the RTC-Manila did not gravely abuse its discretion, ruling that the order to comment itself signified the petition was found acceptable and no separate sufficiency order was mandated. The CA denied reconsideration on August 28, 2014. The Republic, through the AMLC, elevated the case via a Petition for Review on Certiorari, raising a new argument that the Second Verified Petition was prematurely filed before the forfeiture order became final.

ISSUE

Whether the Court of Appeals erred in dismissing the Petition for Certiorari and upholding the RTC-Manila’s Order granting the claims of Teresita Corpus and Teresita Gomez, despite the alleged prematurity of their “Second Verified Petition” and the procedural arguments raised by the AMLC regarding the filing of a comment.

RULING

The Supreme Court denied the Petition for Review. The Court held that the AMLC’s new argument regarding the prematurity of the Second Verified Petition—raised for the first time on appeal—cannot be considered, as questions of fact and law not raised in the lower courts are barred. The only issue properly before the Court was whether the CA correctly found no grave abuse of discretion by the RTC-Manila in its procedural handling of the claim.
On the procedural issue, the Court affirmed the CA’s ruling. It found no grave abuse of discretion in the RTC-Manila’s act of directing the AMLC to comment on the Second Verified Petition without first issuing a separate order declaring it sufficient in form and substance. The Court agreed with the CA’s interpretation that such an order to comment inherently implies the court’s finding of sufficiency, as a patently insufficient petition would be dismissed outright under Section 37 of the Rules on Civil Forfeiture. The AMLC’s Manifestation and Motion was deemed a motion for extension, which is discretionary upon the court. The RTC-Manila’s decision to proceed, considering the AMLC had already been given an opportunity to comment on a prior similar petition, was within its sound discretion and did not amount to a capricious or whimsical exercise of judgment. Therefore, the CA correctly dismissed the Petition for Certiorari.