Case Digest (G.R. No. 157294-95) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Joseph Victor G. Ejercito, then‐Municipal Mayor of San Juan, Manila, filed a petition for certiorari under Rule 65 assailing three resolutions of the Sandiganbayan (Special Division) dated February 7 and 12, 2003 (denying his Motions to Quash Subpoenas Duces Tecum/Ad Testificandum) and March 11, 2003 (denying his Motion for Reconsideration). These subpoenas were issued in Criminal Case No. 26558, “People of the Philippines v. Joseph Ejercito Estrada, et al.,” charging former President Joseph E. Estrada and co‐accused with plunder under R.A. 7080. On January 20, 2003 and January 23, 2003, the Special Prosecution Panel requested subpoenas directed to the President of Export and Industry Bank (formerly Urban Bank) and an authorized representative of Equitable‐PCIBank to produce documents pertaining to (a) Trust Account No. 858 (including account opening papers, trading orders, confirmation advices, microfilm copies, manager’s checks, trust agreement and ledger) and (b) Savings Acco Case Digest (G.R. No. 157294-95) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Plunder Case
- Criminal Case No. 26558 (“People v. Joseph Ejercito Estrada, et al.”) filed in Sandiganbayan for plunder under R.A. 7080 against former President Estrada.
- Special Prosecution Panel requested subpoenas duces tecum/ad testificandum to produce bank records and testimony relating to:
- Trust Account No. 858 (Urban Bank/EIB)
- Savings Account No. 0116-17345-9 (Urban Bank/EIB)
- Petitioner’s Objections and Motions to Quash
- January 27, 2003 – Petitioner JV Ejercito attended hearing and wrote letter citing bank secrecy laws, possible illegal disclosure, and requested ten-day abeyance to secure counsel.
- January 28, February 7, 2003 – Petitioner filed Motions to Quash Subpoenas duces tecum/ad testificandum.
- February 7 & 12, 2003 – Sandiganbayan denied motions.
- March 11, 2003 – Motion for Reconsideration denied.
- Petition for Certiorari Before the Supreme Court
- Filed under Rule 65 to annul Sandiganbayan Resolutions of February 7 & 12 and March 11, 2003.
- Petitioner claimed:
- Accounts are protected by R.A. 1405 and not covered by its exceptions.
- Detailed subpoena requests reveal prior illegal disclosure of bank records (“fruit of the poisonous tree”).
Issues:
- Whether Trust Account No. 858 and Savings Account No. 0116-17345-9 are “deposits” under R.A. 1405.
- Whether these accounts are excepted from confidentiality by R.A. 1405 (competent‐court‐order exception for bribery/dereliction analogues; “subject‐matter” exception).
- Whether the “fruit of the poisonous tree” doctrine or due process rights bar use of detailed information allegedly obtained in prior Ombudsman subpoenas.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)