Title
Estrada vs. Desierto
Case
G.R. No. 146710-15
Decision Date
Mar 2, 2001
Estrada resigned amid corruption allegations, mass protests, and military withdrawal; Arroyo assumed presidency, upheld by Supreme Court as constitutional.

Case Digest (G.R. No. 146710-15)
Expanded Legal Reasoning Model

Facts:

  • Election and Early Term
    • Joseph Ejercito Estrada elected President; Gloria Macapagal-Arroyo elected Vice-President (May 11, 1998).
    • Term began June 30, 1998; initial popularity eroded by 2000.
  • Allegations and Impeachment Proceedings
    • October 4–5, 2000: Ilocos Sur Gov. Luis “Chavit” Singson accuses Estrada of receiving jueteng money and cigarette tax proceeds; Senate Blue Ribbon and Justice Committees investigate.
    • November 13, 2000: House transmits Articles of Impeachment (bribery, graft and corruption, betrayal of public trust, culpable violation of the Constitution) to the Senate; trial opens December 7, 2000.
  • Trial Breakdown and People Power II
    • January 16, 2001: Senate (11–10) refuses to open second envelope containing alleged evidence → prosecutors walk out; trial adjourned indefinitely.
    • January 16–20, 2001: Mass protests at EDSA; AFP and PNP withdraw support; key cabinet members resign.
  • Transfer of Power and Aftermath
    • January 20, 2001: Estrada leaves Malacañang for “peace and healing”; Arroyo sworn in at EDSA Shrine at noon following SC resolution.
    • Post-transition: Congress and foreign governments recognize Arroyo’s presidency; multiple Ombudsman complaints filed against Estrada.

Issues:

  • Justiciability
    • Do the petitions raise a political question beyond judicial review?
    • Can the Court interpret contested constitutional provisions on succession and immunity?
  • Succession and Resignation
    • Did Estrada resign or suffer a permanent disability under Art. VII, Sec. 8?
    • Were Arroyo’s oath and assumption of office valid under the Constitution?
  • Presidential Immunity
    • Is impeachment conviction a prerequisite to criminal prosecution?
    • Does a non-sitting President enjoy post-tenure immunity for official acts?
  • Prejudicial Publicity
    • Should Ombudsman investigations be enjoined for alleged bias from adverse publicity?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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