Case Digest (G.R. No. 241088) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On April 4, 2001, the Office of the Ombudsman filed eight separate informations before the Sandiganbayan, Third Division, charging former President Joseph Ejercito Estrada and several co‐accused with various offenses, including plunder under Republic Act No. 7080 (as amended by R.A. 7659). The amended information in Criminal Case No. 26558 alleged that during his 1998–2001 term, petitioner amassed ill‐gotten wealth exceeding ₱50 million by a combination or series of overt and criminal acts, specifically through (a) collecting P 545 million from illegal gambling, (b) misappropriating P 130 million in tobacco excise taxes, (c) directing stock purchases of Belle Corporation for GSIS and SSS in the total amount of P 1.847 billion for commissions of P 189.7 million, and (d) depositing P 3.233 billion under a dummy account. Petitioner moved to quash the information, alleging that the Plunder Law was unconstitutionally vague and lowered the burden of proof, and that it abolished mens r Case Digest (G.R. No. 241088) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Enactment of the Plunder Law
- Republic Act No. 7080 (1991) defines the crime of plunder: a public officer who amasses at least ₱50 million in ill-gotten wealth through a combination or series of enumerated means (misappropriation, bribery, fraudulent disposition, stock dealings, monopolies, undue influence) faces reclusion perpetua to death.
- Republic Act No. 7659 (1993) amended RA 7080 to impose death on certain heinous crimes, including plunder.
- Charges and Procedural History
- April 4 2001: Ombudsman filed eight informations against former President Joseph Estrada before the Sandiganbayan, including Crim. Case No. 26558 for plunder under RA 7080.
- Estrada’s omnibus motion sought remand for preliminary investigation and reconsideration (Apr 11); Sandiganbayan found probable cause and denied it (Apr 25, May 31).
- June 14: Estrada moved to quash the plunder information on grounds of constitutional infirmity and multiplicity of offenses; motion denied (July 9).
- Petition for Certiorari
- Estrada filed a Rule 65 petition before the Supreme Court challenging Sections 1(d), 2 and 4 of RA 7080 as vague, overbroad, dispensing with reasonable-doubt proof and abolishing mens rea for underlying offenses.
- The Supreme Court en banc required respondents’ comments, heard oral arguments (Sept 18 2001), and received memoranda regarding validity of the Plunder Law.
Issues:
- Vagueness and Overbreadth
- Whether RA 7080’s key phrases (“combination or series,” “pattern of overt or criminal acts”) are so vague/overbroad as to violate due process and the right to know the nature and cause of accusations.
- Standard of Proof
- Whether Section 4 of RA 7080 impermissibly lowers the prosecution’s burden by not requiring proof of each criminal act and thus violates the presumption of innocence.
- Mens Rea Requirement
- Whether RA 7080 unconstitutionally eliminates criminal intent (mens rea) for its predicate offenses, converting mala in se crimes into mala prohibita.
Ruling:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)