Primary Holding

The Supreme Court adjudicated that the PCGG lacked the requisite jurisdiction to investigate and prosecute Major General Ramas and Elizabeth Dimaano, as Ramas did not meet the definitional criteria of a "subordinate" of former President Ferdinand Marcos under Executive Orders Nos. 1, 2, 14, and 14-A. The Court affirmed that such jurisdiction rightly resides with the Office of the Ombudsman and the Office of the Solicitor General.

Background

In the aftermath of the 1986 EDSA Revolution, President Corazon Aquino established the PCGG to spearhead the recovery of assets unlawfully acquired during the Marcos regime. The AFP Anti-Graft Board, under the PCGG's directive, initiated an inquiry into the financial dealings of Major General Ramas, uncovering properties and assets allegedly disproportionate to his lawful income. The investigation extended to Elizabeth Dimaano, purportedly Ramas' mistress, in whose possession substantial monetary sums and military-grade equipment were discovered. This led to a forfeiture petition grounded on the Anti-Graft and Corrupt Practices Act and the Forfeiture Law (RA No. 1379).

Facts

• 1. Major General Ramas owned multiple properties and held substantial assets incongruent with his official income as a military officer.
• 2. A significant sum of cash (PHP 2,870,000 and USD 50,000), along with military communication equipment and land titles, were confiscated from Dimaano's residence.
• 3. Evidence presented included testimonies from military personnel, affidavits linking Ramas to Dimaano, and documentation of the seized assets.

Arguments of the Petitioners

• 1. Asserted the existence of a prima facie case of ill-gotten wealth, evidenced by the disproportion between Ramas' assets and his legitimate income.
• 2. Argued that Ramas' high-ranking military position inherently established his status as a subordinate of Marcos, justifying the PCGG's jurisdiction.
• 3. Contended that the items seized during the search were lawfully admissible in court proceedings.

Arguments of the Respondents

• 1. Challenged the PCGG's jurisdiction, asserting that Ramas lacked a direct and substantial subordinate relationship to Marcos as required under the relevant executive orders.
• 2. Argued that the evidence was inadmissible, having been obtained through an unlawful search and seizure devoid of proper judicial authorization.
• 3. Disputed the establishment of a prima facie case, claiming the absence of concrete evidence linking the assets to illicit activities.

Issues

• 1. Whether the PCGG had the legal authority to investigate and prosecute Ramas and Dimaano.
• 2. Whether the dismissal of the forfeiture case prior to the completion of the presentation of evidence was procedurally justified.
• 3. Whether the evidence obtained from Dimaano's residence was admissible in light of constitutional protections against unlawful search and seizure.

Ruling

• 1. The Supreme Court ruled that the PCGG lacked jurisdiction because Ramas did not qualify as a "subordinate" or associate of Marcos within the legal meaning established by EO No. 1 and its amendments.
• 2. The dismissal of the case was deemed procedurally proper due to protracted delays attributed to the petitioner's lack of diligence and the fundamental jurisdictional defect.
• 3. The Court held that the seized evidence was inadmissible, having been obtained through a search that violated constitutional safeguards against unreasonable searches and seizures.

Doctrines

• 1. Ejusdem Generis: This doctrine was invoked to limit the interpretation of "subordinate" to those individuals with demonstrable and close affiliations with former President Marcos, excluding mere positional subordination without substantive personal or professional ties.
• 2. Exclusionary Rule: The rule mandates the inadmissibility of evidence obtained through unconstitutional methods, specifically addressing the unlawful seizure of property without valid judicial authorization.

Key Excerpts

• 1. “The rule of law mandates that an agency of government be allowed to exercise only the powers granted to it.”
• 2. “Jurisdiction is conferred by law, not by the acquiescence or consent of the parties.”

Precedents Cited

• 1. Republic v. Migrino: Clarified the jurisdictional limitations of the PCGG, particularly concerning the investigation of military officials not directly connected to the Marcos administration.
• 2. Cruz, Jr. v. Sandiganbayan: Examined the scope of the PCGG’s investigative authority, reinforcing the need for clear subordinate relationships to justify jurisdiction.

Statutory and Constitutional Provisions

• 1. Republic Act No. 1379: Governs the forfeiture of unlawfully acquired property, establishing the legal framework for such actions.
• 2. Republic Act No. 3019: The Anti-Graft and Corrupt Practices Act, providing legal grounds for prosecuting corruption-related offenses.
• 3. Executive Orders Nos. 1, 2, 14, 14-A: Define the establishment, powers, and operational scope of the PCGG in relation to recovering ill-gotten wealth.