Estate of Ferdinand E. Marcos v. Republic, G.R. No. 213027, January 18, 2017; Imelda Marcos and Irene Marcos-Araneta v. Republic, G.R. No. 213253, January 18, 2017

FACTS: The 1991 Petition sought the recovery of properties pertaining to the Marcoses, who acquired them through and/or as the result of the improper or illegal use of funds or properties owned by the Philippine government. Some of these properties were already adjudged by the Supreme Court as ill-gotten wealth and were subsequently forfeited in favor of the government.

The Sandiganbayan categorized the recovered pieces of jewelry into three (3) collections, namely the “Hawaii Collection,” “Roumeliotes Collection,” and “Malacañang Collection.” The said collections were estimated to be worth between US$ 5,313.575 to US$ 7,112,879 at the time of the filing of the petition. The Malacañang Collection, which was seized after the People Power Revolution on February 25, 1986, was the object of the forfeiture proceeding.

ISSUE: Whether or not the Malacañang Collection may be the subject of the forfeiture case.

RULING: Yes. The Sandiganbayan correctly held that the forfeiture was justified and that the Malacañang Collection was subject to forfeiture. The properties were included in the 1991 Petition as found under paragraph 9(6), which states: “However, the other properties which had been identified so far by both the PCGG and the Solicitor General (excluding those involved in the aforesaid civil cases) are approximated at US$5-B and which include –– (6) Paintings and silverware sold at public auction in the United States worth $17-M, aside from the jewelries, paintings and other valuable decorative arts found in Malacañang and in the United States estimated to be about $23.9-M…” Hence, the 1991 Petition is compliant with the requirements as provided in the law and jurisprudence. Furthermore, Section 2 of Republic Act No. 1379 provides: “Whenever any public officer or employee has acquired during his incumbency an amount of property which is manifestly out of proportion to his salary as such public officer or employee and to his other lawful income and the income from legitimately acquired property, said property shall be presumed prima facie to have been unlawfully acquired.” The Sandiganbayan took judicial notice of the legitimate income of the Marcoses during their incumbency as public officers from 1966 to 1986 that was pegged at US$ 304,372.43. Petitioners failed to satisfactorily show that the properties were lawfully acquired. Thus, the prima facie presumption that they were unlawfully acquired prevails.