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Keywords

tortplaintiffdamagesliabilitytrialcorporationjury trialact of state doctrine
plaintifftrialcorporation

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Roxas v. Marcos, 89 Hawai‘i 91, 969 P.2d 1209

Facts

Rogelio Roxas, a locksmith and treasure hunter, discovered a golden buddha statue and gold bars believed to be part of the Yamashita Treasure in the Philippines. After reporting his find, Roxas was subjected to a violent raid by Philippine authorities, allegedly ordered by Ferdinand Marcos, during which his treasure was seized. Following the raid, Roxas faced torture and intimidation to force him to relinquish information about the treasure. After years of legal battles, Roxas and his estate sued the Marcoses for conversion and other claims, leading to a jury trial and significant damages awarded to Roxas.

Rogelio Roxas, a locksmith and treasure hunter, discovered a golden buddha statue and gold bars believed to be part of the Yamashita Treasure in the Philippines.

Issue

The main legal issues included whether Philippine law applied, the validity of Imelda Marcos's substitution as a party, the enforceability of the judgment against the Marcos estate, and the sufficiency of evidence for the damages awarded.

The main legal issue(s) or question(s) the court needed to resolve.

Rule

The court ruled that while Philippine law was applicable, Hawai‘i law would be applied where Philippine law was not adequately addressed. It also held that Imelda's status as an heir did not automatically support her substitution as a party, and that the act of state doctrine and head of state immunity did not bar claims against the Marcoses.

The court ruled that while Philippine law was applicable, Hawai‘i law would be applied where Philippine law was not adequately addressed.

Analysis

The court analyzed the evidence presented at trial, determining that the jury's findings of battery, false imprisonment, and conversion were supported by sufficient evidence. It also found that the damages awarded for the conversion of the golden buddha were justified, while the evidence for the storage area of gold was deemed speculative. The court concluded that Imelda was judicially estopped from denying personal liability due to her conduct during the proceedings.

The court analyzed the evidence presented at trial, determining that the jury's findings of battery, false imprisonment, and conversion were supported by sufficient evidence.

Conclusion

The court affirmed in part and reversed in part the lower court's judgment, remanding the case for further proceedings regarding the valuation of the converted property and the award of prejudgment interest.

The court affirmed in part, reversed in part, and remanded.

Who won?

The plaintiffs, represented by the Roxas Estate and the Golden Budha Corporation, prevailed in part due to the court's affirmation of the jury's findings on battery, false imprisonment, and conversion, as well as the support for the damages awarded for the golden buddha.

The plaintiffs, represented by the Roxas Estate and the Golden Budha Corporation, prevailed in part due to the court's affirmation of the jury's findings on battery, false imprisonment, and conversion.

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