G.R. No. 84195 . December 11, 1989.
LUCIO C. TAN, ET AL., petitioners, vs. SANDIGANBAYAN (Second Division) and REPUBLIC OF THE PHILIPPINES (Represented by the PCGG), respondents.

FACTS

The Presidential Commission on Good Government (PCGG) filed a Complaint, later expanded, against petitioners Lucio C. Tan and twenty-one others, along with Ferdinand Marcos, Imelda Marcos, and others. The complaint alleged five causes of action: Abuse of Right and Power, Unjust Enrichment, Breach of Public Trust, Accounting, and a catch-all cause. It sought the return of allegedly ill-gotten wealth, accounting, and the payment of massive damages, including P50 billion in moral damages. Petitioners filed a Motion for a More Definite Statement or a Bill of Particulars, arguing the complaint’s allegations were vague, ambiguous, and lacked specific details on the acts committed, the properties involved, and the legal basis for their liability as non-public officers.
The Sandiganbayan denied the motion. It found the expanded complaint, read together with its annexes, sufficiently informative. The court also issued a Resolution interconnecting the complaint’s paragraphs to clarify the causes of action. Petitioners elevated the denial to the Supreme Court via certiorari, contending the Sandiganbayan acted with grave abuse of discretion, as the complaint failed to state a cause of action against them with the requisite specificity, violating their constitutional right to be informed of the nature and cause of the accusation.

ISSUE

Whether the Sandiganbayan committed grave abuse of discretion in denying the petitioners’ Motion for a More Definite Statement or a Bill of Particulars.

RULING

No, the Sandiganbayan did not commit grave abuse of discretion. The Court ruled that a motion for a bill of particulars is intended to secure more specific allegations to enable a party to properly prepare a responsive pleading, not to obtain evidentiary details. The test is whether the complaint is sufficiently definite to enable a defendant to prepare an answer. The Court examined the expanded complaint and found it detailed enough for its purpose. It narrated a series of acts purportedly done in unlawful concert with the Marcoses to accumulate wealth, specifying corporate vehicles, financial transactions, and regulatory manipulations.
The Court held that while the complaint was “garbled in many respects,” the Sandiganbayan had already taken corrective steps by issuing a resolution to interconnect its allegations. The complaint, as clarified, provided petitioners adequate notice of the claims against them, preventing surprise during trial. The demand for excessive minutiae at the pleading stage was unwarranted. The causes of action, though broadly framed under civil law principles like constructive trust and unjust enrichment, were anchored on factual averments of specific collaborative schemes. Therefore, the Sandiganbayan’s order for petitioners to answer was proper, and the case was ordered remanded for trial without further delay. The petition was dismissed.