Case Digest (G.R. No. 148560)
Facts:
Joseph Ejercito Estrada v. Sandiganbayan (Third Division) and People of the Philippines, G.R. No. 148560, November 19, 2001, Supreme Court En Banc, Bellosillo, J., writing for the Court.Petitioner Joseph Ejercito Estrada, a former President, was charged by the Office of the Ombudsman with plunder and related offenses; the Ombudsman filed eight informations on April 4, 2001, including Criminal Case No. 26558 (plunder) under R.A. No. 7080 (the Plunder Law), as amended by R.A. No. 7659. The Amended Information alleged that from June 1998 to January 2001 Estrada, alone or in connivance, amassed ill‑gotten wealth of about P4.097 billion through a “combination or series of overt or criminal acts” (e.g., receipt of jueteng money; diversion/misuse of tobacco excise shares; stock purchases for GSIS/SSS and commissions; deposits under the name “Jose Velarde”).
Petitioner moved to remand certain matters and later filed a Motion to Quash (June 14, 2001) arguing that R.A. 7080 was void for vagueness, lowered the reasonable‑doubt standard (Sec. 4), and abolished mens rea for mala in se crimes. The Sandiganbayan (Third Division) found probable cause (Resolution, Apr. 25, 2001), denied reconsideration (June 25, 2001), and denied the Motion to Quash (Resolution of July 9, 2001). Petitioner filed a petition for certiorari (Rule 65) before the Supreme Court attacking the Sandiganbayan’s denial and raising the statute’s constitutionality.
Oral arguments were heard September 18, 2001. The Court framed the issues as: (1) whether R.A. 7080 is vague; (2) whether Sec. 4 lowers the quantum of proof and vio...(Subscriber-Only)
Issues:
- Is R.A. No. 7080 (the Plunder Law) unconstitutional for vagueness in violation of due process?
- Does Section 4 of R.A. No. 7080 unlawfully lower the quantum of proof (avoid proof of each predicate act) and thus violate the accused’s right to due process?
- Is the crime of plunder, as defined in R.A. No. 7080, a malum prohibitum offense (thereby dispensing with mens rea), and if so, may Congres...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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