Case Summary (G.R. No. 146710-15)
Petitioner
Joseph E. Estrada seeks declarations that he remains the lawful President (albeit on leave), challenges Gloria Macapagal-Arroyo’s assumption of office, and prays for injunctive relief against the Ombudsman’s criminal proceedings.
Respondents
• Gloria Macapagal-Arroyo – Claiming to be the duly sworn-in President of the Republic.
• Ombudsman Desierto and private complainants – Defending the conduct of graft and plunder investigations against Estrada.
Key Dates
• June 30, 1998 – Estrada and Arroyo begin six-year term.
• October 4–17, 2000 – Corruption exposés by Gov. Singson; mass calls for Estrada’s resignation.
• November 13, 2000 – House impeaches Estrada (115 signatures).
• December 7, 2000 – Impeachment trial opens in the Senate.
• January 16, 2001 – Senate trial halted by 11-10 vote refusing to open envelope; prosecution walks out.
• January 20, 2001 – Arroyo sworn in at EDSA Shrine; Estrada departs Malacañang.
Applicable Law
• 1987 Constitution (post-1990 case) – Article II (sovereignty), Article VII (presidential succession, vacancy in the presidency, acting capacity, immunity), Article XI (public officers’ accountability), Article XVII (amendment process).
• RA No. 3019 (Anti-Graft and Corrupt Practices Act) – No resignation pending investigation/prosecution.
• Political-question doctrine; executive immunity precedents (Forbes v. Tiaco, Nixon v. Fitzgerald, etc.); rules on injunctive relief in criminal matters.
Factual Background and People Power II
A cascade of corruption allegations led to coordinated Senate and House inquiries and an impeachment. When a critical evidentiary envelope remained sealed on January 16, public outrage reignited mass protests at EDSA (People Power II). Government officials, military and police chiefs withdrew support, and Estrada’s moral authority collapsed.
Impeachment Proceedings and Abrupt Termination
The Senate, sitting as an impeachment court, began trial December 7, 2000. On January 16, 2001, by 11-10 vote, senators refused to open the second envelope containing bank evidence. Public and private prosecutors walked out, Senate President Pimentel resigned, and the tribunal adjourned indefinitely.
Crisis of Governance and Transition Negotiations
Between January 19–20 intermediaries negotiated a peaceful handover: a transition period, security guarantees for Estrada and family, and opening of the sealed envelope. The deal collapsed when the Supreme Court confirmed Arroyo’s right to be sworn in as President at noon on January 20.
Resignation and Permanent Disability Analysis
Estrada issued a press statement leaving Malacañang “for the sake of peace” without reservation. He also sent written declarations to congressional leaders claiming inability to discharge presidential duties. The Court applied Article VII, Sections 8 and 11, interpreting permanent disability to include loss of moral and institutional support, validating succession by resignation and vacancy. Temporary leave arguments were rejected as inconsistent with the totality of events.
Constitutional Succession under Article VII
– Section 8: Vice-President becomes President upon death, permanent disability, removal, or resignation of the President.
– Section 11: Vice-President acts during written declaration of inability by the President or majority Cabinet certification, with Congress as final arbiter.
Estrada’s de facto “resignation” and permanent disablement triggered Section 8; Arroyo’s swearing-in was constitutionally grounded.
Judicial Doctrines on Political Questions and Justiciability
The Court rejected political-question defenses, distinguishing EDSA I (extra-constitutional revolution) from EDSA II (constitutional redress via free speech and assembly). Interbranch disputes over succession are within judicial review under Article VIII (grave abuse of discretion) and Marbury v. Madison principles.
Decision and
Case Syllabus (G.R. No. 146710-15)
Facts and Procedural History
- In February 2001 Estrada filed (1) a petition for prohibition (G.R. Nos. 146710-15) with prayer for writ of preliminary injunction to stop the Ombudsman from investigating six complaints, and (2) a petition for quo warranto (G.R. No. 146738) declaring him the lawful President and Arroyo only Acting President.
- On February 6, 2001 the Court required respondents to comment; on February 13 it consolidated the two cases and set oral argument for February 15.
- By Resolution of the en banc Court on February 20, 2001, a 30-day status-quo order was issued restraining the Ombudsman from deciding the pending criminal cases against petitioner pending decision of the consolidated petitions.
Political and Constitutional Background
- May 11, 1998: Estrada elected President; Arroyo elected Vice-President for a six-year term starting June 30, 1998.
- October 4-5, 2000: Governor Chavit Singson’s exposé and Senator Guingona’s “I Accuse” privilege speech led to Senate Blue Ribbon and House investigations.
- November 13, 2000: House transmitted Articles of Impeachment signed by 115 representatives to the Senate.
- December 7, 2000: Impeachment trial before 21 senator-judges began.
- January 16, 2001: Senate refused to open the second envelope; prosecution team walked out; trial postponed indefinitely.
- January 17-19, 2001: Mass rallies at EDSA Shrine and Ayala Avenue; mass resignations/defections from Estrada’s camp.
- January 20, 2001: Chief Justice Davide administered the oath to Arroyo as President at EDSA Shrine; Estrada left MalacaAang Palace and issued a press statement; he also transmitted a letter to Congress declaring his temporary inability to perform presidential duties.
- January 22, 2001: Court issued Administrative Resolution confirming authority of Chief Justice to administer Arroyo’s oath, without prejudice to petitions challenging her presidency.
Constitutional and Legal Issues
- Whether the controversy is justiciable or a non-reviewable political question.
- Whether petitioner Estrada validly resigned or became permanently disabled, creating a constitutional vacancy under Art. VII, Sec. 8.
- Whether Estrada was merely temporarily unable to discharge presidential duties and thus Arroyo served only as Acting President under Art. VII, Sec. 11.
- Whether impeachment conviction is a condition precedent to criminal prose