A ruling by the Supreme Court (SC) holds that wealth acquired by a public officer during their time in office that exceeds lawful income is presumed ill-gotten and may be forfeited—even if registered under the names of other individuals.

In a decision dated 5 March 2025 and written by Associate Justice Japar B. Dimaampao, the SC’s Third Division upheld the forfeiture of properties, bank deposits, and investment accounts under the name of retired Lieutenant General Jacinto C. Ligot, as well as assets traced to him but registered under his wife, children, and relatives.

Ligot served in the Armed Forces of the Philippines from 1970 until his retirement in 2004, and was a commissioned comptroller during the relevant period. The Office of the Ombudsman conducted a lifestyle investigation to determine whether the properties he acquired during active service exceeded his salary and other lawful income.

Ligot’s declared assets in his Statements of Assets, Liabilities, and Net Worth (SALNs) from 1982 to 2003 did not reflect the actual properties under his name and those of his close family members, prompting the Ombudsman to file a petition for forfeiture before the Sandiganbayan. The petition also named his wife, their children, and his sister and brother-in-law, who were allegedly used as fronts to conceal his assets.

The Sandiganbayan found several undeclared properties registered under General Ligot’s name and/or his wife, along with additional undeclared properties registered under their children’s names. It also traced several condominium units to the family: units in Makati City under his sister’s name—where most amortization payments were made by General Ligot and his wife—and a unit in Taguig City registered under his brother-in-law, which had originally been purchased by Ligot’s wife.

Ligot and his family were likewise implicated in a petition for forfeiture alleging that bank deposits and investment accounts under their names were manifestly out of proportion to the general’s lawful income. The Sandiganbayan ruled that the properties, worth ₱102 million, and deposits and investment funds amounting to ₱53 million, were unlawfully acquired and ordered their forfeiture.

General Ligot and his family elevated the case to the SC, arguing that the condominium units were not his and had been legitimately purchased by his relatives. They also claimed that the deposits and investments were proportionate to the family’s income. During the pendency of the petition, Ligot passed away, but his family continued to pursue the case.

His sister and brother-in-law also filed their own petitions, insisting that they owned the condominium units and should not be included in the forfeiture ruling. The high bench rejected these claims and affirmed the Sandiganbayan’s decision.

The Court noted that Ligot’s wife and children did not have independent income sources yet owned properties and maintained significant bank and investment accounts. As for the condominiums, although titled under his sister’s name, amortizations were paid by General Ligot. The condominium under his brother-in-law’s name had originally been bought by Ligot’s wife, who likewise lacked personal income.

The SC held that these circumstances showed that Ligot was the true owner, even if legal titles were placed under other people’s names.

Under Republic Act No. 1379, properties of public officers are presumed illegally acquired when they are manifestly out of proportion to lawful income. This presumption applies not only to properties registered under the officer’s name but also to those hidden or transferred to others, so long as true ownership can be traced back to the official.

The Court explained that “RA 1379 would be rendered ineffectual if the registration of properties in the name of third persons would suffice to forestall the presumption under Section 2 of the law from arising,” emphasizing that registration under another person’s name does not prevent forfeiture when true ownership is established.