21/11/2025
The has ruled that wealth acquired by a public officer during their time in office that clearly exceeds their lawful income is presumed unlawfully acquired and may be forfeited, even if registered under the names of other individuals.
In a Decision written by Associate Justice Japar B. Dimaampao, the SCโs Third Division upheld the forfeiture of properties, bank deposits, and investment accounts in the name of retired Lieutenant General Jacinto C. Ligot (General Ligot), as well as assets traced to him but registered under his wife, children, and relatives.
The Ombudsman conducted a lifestyle investigation on General Ligotโwho served in the Armed Forces of the Philippines from 1970 until his retirement in 2004, and was a commissioned comptroller during the relevant periodโto determine whether the properties he acquired during active service exceeded his salary and other lawful income.
Its probe into General Ligotโs declared assets in his Statements of Assets, Liabilities, and Net Worth from 1982 to 2003, which did not reflect the actual properties under his name and those of his close family members, led to a petition for forfeiture filed against him before the Sandiganbayan. Also named in the petition were his wife, their children, and his sister and brother-in-law, who were allegedly used as fronts to conceal his assets.
The Sandiganbayan ordered the forfeiture of the properties worth PHP 102 million as well as deposits and investment funds amounting to PHP 53 million after finding that the same were unlawfully acquired.
The SC upheld the Sandiganbayanโs ruling, noting that General Ligotโs wife and children did not have independent income sources but still owned properties and held significant bank and investment accounts under their names.
Regarding the condominiums, even though they were titled in his sisterโs name, the amortizations were paid by General Ligot. The condominium listed under his brother-in-lawโs name was initially bought by General Ligotโs wife, who lacked her own income.
The SC held that these circumstances indicate that General Ligot was the true owner, even if the legal titles were in other peopleโs names.
Under Republic Act No. 1379, properties of public officers are presumed to be illegally acquired when they are manifestly out of proportion to their lawful income.
This presumption applies not only to properties under the public officerโs name but also to those hidden or transferred to others, as long as true ownership can be traced to the public officer.
The SC emphasized that registration under another personโs name does not prevent forfeiture when true ownership can be traced to the public officer.
Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=155660.
Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=155651.
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