Case Digest (G.R. No. 185729-32)
Facts:
In G.R. Nos. 146710-15 and G.R. No. 146738, former President Joseph E. Estrada filed, on March 9 and March 22, 2001, respectively, a Motion for Reconsideration and an Omnibus Motion challenging this Court’s March 2, 2001 Decision which (1) denied his petition to enjoin the preliminary investigation of Ombudsman Aniano Desierto and related respondents, and (2) confirmed that Vice-President Gloria Macapagal-Arroyo lawfully succeeded him as President on January 20, 2001. Estrada alleged among others that (a) his absolute immunity and double-jeopardy rights were ignored, (b) impeachment immunity under Art. XI, Sec. 3(7) of the 1987 Constitution barred subsequent prosecution, (c) due-process rights were prejudiced by pre-trial publicity, (d) the Angara Diary and newspaper accounts were inadmissible hearsay and violated the best-evidence and authentication rules, (e) Congress had no authority to decide his alleged temporary inability to govern, and (f) he never resigned on January 20Case Digest (G.R. No. 185729-32)
Facts:
- Procedural Posture
- On March 2, 2001, the Supreme Court en banc rendered a Decision in G.R. Nos. 146710–15 (Estrada vs. Desierto et al.) and G.R. No. 146738 (Estrada vs. Macapagal-Arroyo), denying petitioner’s motions for injunctive relief and declaring the vacancy of the presidency.
- Petitioner filed a Motion for Reconsideration (G.R. Nos. 146710–15) and an Omnibus Motion (G.R. No. 146738) raising constitutional, procedural, and evidentiary issues.
- Background Events Leading to the Transfer of Power
- Prior to January 20, 2001, a series of events eroded confidence in President Estrada:
- The “Chavit Singson” expose (Oct. 4, 2000), Senator Guingona’s “I accuse” speech, and concurrent congressional and Senate investigations.
- Pastoral letters and public demands for resignation by clergy, former Presidents Aquino and Ramos, and leaders in government and business.
- Mass defections from Estrada’s party, resignation of key Cabinet members, and mounting street protests culminating in rallies at EDSA.
- Contemporaneous Events on January 20, 2001
- Vice-President Arroyo took her oath as President at 12:28 P.M.
- Secretary Angara’s private diary (“Angara Diary”) recorded Estrada’s changing position, proposals for snap elections, and expressions of fatigue and intent to vacate Malacañang.
- Subsequent Events
- Estrada issued a press release after noon declaring his purported continuance but abandoned Malacañang for Greenhills.
- Congress issued concurrent resolutions recognizing Arroyo as constitutional successor and confirmed the vacancy and legislative acts (e.g., nomination of Vice-President Guingona).
Issues:
- Constitutional Immunity
- Whether the Court disregarded Art. XI, § 3(7) on impeachment and subsequent criminal prosecution.
- Double Jeopardy
- Whether impeachment acquittal bars criminal prosecution under the Double Jeopardy Clause.
- Absolute Immunity
- Whether petitioner retains absolute immunity from suit as President on leave or by virtue of his term.
- Pre-Trial Publicity
- Whether pervasive publicity violated petitioner’s right to due process and a fair preliminary investigation.
- Injunction Against Ombudsman Investigation
- Whether there was sufficient evidence to enjoin the Ombudsman’s preliminary probe for bias.
- Resignation as Vacancy
- Whether petitioner resigned or must be deemed resigned as of January 20, 2001.
- Admissibility of the Angara Diary
- Whether the Angara Diary violates rules on hearsay, best evidence, authentication, admissions, and res inter alios acta.
- Newspaper Accounts
- Whether reliance on press reports is hearsay.
- Congressional Determination of Inability
- Whether post facto congressional acts deciding petitioner’s inability to govern contravene Art. VII, §§ 8 and 11.
- Additional Pre-Judicial Publicity
- Whether media coverage of the preliminary investigation before the Ombudsman prejudiced the decision-makers.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)