Case Digest (G.R. No. 148965)
Facts:
Jose Jinggoy E. Estrada v. Sandiganbayan (Third Division), G.R. No. 148965, February 26, 2002, the Supreme Court En Banc, Puno, J., writing for the Court. The petition assails resolutions of the Sandiganbayan (Third Division) that sustained an Amended Information for plunder filed by the Office of the Ombudsman and denied petitioner reliefs including exclusion from the Information and bail.In November 2000 several criminal complaints grew out of impeachment proceedings against then President Joseph Ejercito Estrada. On April 4, 2001 the Ombudsman issued a Joint Resolution finding probable cause to file several Informations with the Sandiganbayan; one Amended Information (filed April 18, 2001) charged former President Estrada and others, including petitioner Jose Jinggoy Estrada (then Mayor of San Juan), with plunder under R.A. No. 7080, as amended by Sec. 12 of R.A. No. 7659. The Amended Information set out a general conspiracy allegation and four sub-paragraphs (a)–(d) describing predicate acts; petitioner’s name appears specifically in sub-paragraph (a) alleging the receipt, on several instances, of money from illegal gambling (jueteng) forming part of an aggregate P545 million.
After the Ombudsman’s filing, the Sandiganbayan issued a warrant of arrest (April 25, 2001). Petitioner filed motions in the Sandiganbayan: a Motion to Quash or Suspend (April 24, 2001), a Very Urgent Omnibus Motion (April 30, 2001) arguing lack of probable cause and asserting a right to bail, and other motions relating to bail and incidents. The Sandiganbayan denied the motion to quash and the omnibus motion by Resolution dated July 9, 2001 (setting the alternative bail prayer for hearing after arraignment). Petitioner’s motion for reconsideration was denied; he refused to plead at arraignment on July 10, 2001 and the court entered a plea of not guilty for him.
Petitioner renewed bail motions (including an Urgent Second Motion for Bail for Medical Reasons filed August 14, 2001). The Sandiganbayan conducted medical hearings in September 2001 and, by Resolution dated December 20, 2001, denied bail for lack of factual basis. Petitioner then filed a petition with the Supreme Court (a petition for certiorari challenging the Sandiganbayan’s actions and seeking exclusion from the Information and/or bail). The Court required the Sandiganbayan to report (December 2001)...(Pro-only)
Issues:
- Did the Sandiganbayan act without or in excess of jurisdiction or with grave abuse of discretion amounting to lack of jurisdiction by declining to declare R.A. No. 7080 unconstitutional and by denying petitioner equal protection?
- Was the Amended Information legally insufficient—i.e., did it fail to charge petitioner with a “series or combination” of overt acts as required for plunder under R.A. No. 7080, or otherwise fail to allege conspiracy with the requisite particularity?
- Did the Sandiganbayan err in denying bail to petitioner, who allege...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)