Solicitor General Ricardo Galvez yesterday said the dictator's heirs could no longer question the Supreme Court ruling ordering them to pay P23.5 billion in unpaid income and inheritance taxes.

''They have no other remedy available but to pay the taxes,'' Galvez told the Inquirer a day after the government scored its biggest victory against the Marcoses who, for the past 13 years, had frustrated its efforts to recover the bulk of their alleged ill-gotten wealth.

Yesterday, President Estrada told reporters the government would collect the unpaid taxes of the Marcoses once the Supreme Court ruling became final.

Galvez said the BIR could now proceed with the public auction of these properties. ''If they are not sufficient, the BIR can go after the Marcoses' other real property, if they can find any,'' he said.

The BIR tried to auction off 11 of the 30 pieces of properties in 1993, but there were no bidders. These parcels of land, mostly in Imelda Marcos's home province of Leyte, were then forfeited in the government's favor.

For years, the Marcoses had refused to admit ownership of the properties. It was only after the auction that the Marcoses questioned the BIR's actions in court--and the wrong one at that.

The other Marcos properties facing seizure include the Marcoses' Pacific Plaza property in Makati City.

Galvez said he did not know where the other Marcos properties were located.

The Marcoses were taken aback by the landmark ruling of the Supreme Court's Third Division.

''It's too hard to accept that we lost on a technicality,'' said the dictator's daughter, Ilocos Norte Rep. Imee Marcos, who described tax deficiency assessment as ''excessive.''

''I don't know how we will approach this thing,'' Ilocos Norte Gov. Ferdinand Marcos Jr. also told the Inquirer. ''I also don't know how this will impact in the settlement issues which are supposed to be happening.''

The matriarch, former first lady Imelda Marcos, could not be reached for comment.

The high court denied three appeals by Ferdinand Marcos Jr. and his mother, Imelda, against the Bureau of Internal Revenue's seizure of 30 parcels of land to cover the family's unpaid taxes.

The BIR served the levies on the Marcos properties in February to May 1993 after its special tax audit team determined the Marcoses had failed to pay P23.2 billion in inheritance tax for property left behind by the late president. He died in Hawaii in 1989, four years after he and his family fled the Philippines at the height of the Edsa ''People Power'' Revolt.

The BIR team also said the Marcos couple and their son had unpaid income taxes amounting to about P300 million for the 1982-86 period.

In its ruling, the high court said the Marcos heirs filed their appeals too late and at the wrong venue. It said the Marcoses should have questioned the BIR's tax assessment before the bureau or the Court of Tax Appeals instead of seeking a restraining order with the Court of Appeals to stop the tax collection.

''No other person than the petitioner is to blame for the expiration of the period within which to question the assessments,'' the court said.

Imee

For her part, Imee Marcos said estimates of his father's wealth were exaggerated, adding that the government had no actual data.

''It seems they know better how much my father left behind,'' she said. ''The assessment was too much.''

Last week, President Estrada estimated that the Marcos wealth exceeded $10 billion and might be as high as $15 billion.

Bongbong

In Muñoz, Nueva Ecija, Governor Marcos said the issue of the P23.5 billion in unpaid taxes might be included in negotiations for a compromise settlement with the government.

The young Marcos, one of the conference speakers at the Philippine Rice Research Institute here, said his family has scheduled talks with Mr. Estrada.

''The truth is we haven't really spoken to the President yet. So none of these issues has been raised. Eventually, this issue might be included in the talks,'' he said.

Like his sister, Marcos questioned how the BIR came up with the P23.5-billion tax assessment. ''They don't even know how big is the Marcos estate,'' he said.

It was this same argument that the Supreme Court threw out of the window.

When the Marcoses appealed the high court's decision in August 1995, they claimed that a Pasig probate court had yet to determine the value of the Marcos estate, on which the BIR should have based its tax assessment.

In June 1997, the Supreme Court denied the Marcoses' petition. Imelda Marcos and her son immediately filed their appeal. On Sept. 29, 1997, the high court again ruled against the Marcoses' petition for lack of merit.

In November and December 1997, Governor Marcos and his mother filed their separate motions for reconsideration. The high tribunal denied their appeal in a four-page resolution dated Jan. 13, 1999, and declared its decision final and executory.

Alvarez

For his part, Isabela Rep. Heherson Alvarez said that any compromise agreement between the government and the Marcoses at this time would be ''tantamount to an empty, sterile (agreement) and (would be) morally injurious to our national interest.''

According to him, the Supreme Court decision has all but left the ''(Marcos) estate and family no money to pay its obligation in a compromise agreement.''

Alvarez said he had filed a House resolution ''asking President Estrada to instruct the Presidential Commission on Good Government and all relevant instrumentalities to desist from brokering or concluding any compromise agreement'' with the Marcoses.

He said the Marcoses did not owe the government only P23.47 billion in back taxes but P70 billion.

According to him, the Supreme Court failed to include more than P46 billion in annual surcharge for the unpaid taxes from June 1990, when the assessment was made, to Jan. 13, 1999 when the final judgment was made.

''This collectible amount in taxes of P70 billion exceeds the $580 million held in escrow by P47 billion under the present peso-dollar exchange rate,'' he said.

By Donna S. Cueto, with reports from Rocky Nazareno and Martin Marfil in Manila, Anselmo Roque/PDI Central Luzon; and Inquirer wires