Title
People vs. Estrada
Case
G.R. No. 164368-69
Decision Date
Apr 2, 2009
Ex-Philippine President Estrada acquitted of illegal alias use; court ruled alias "Jose Velarde" in private banking lacked public, habitual use under applicable laws.

Case Summary (G.R. No. 251732)

Petitioner

People of the Philippines

Respondent

Joseph Ejercito Estrada

Key Dates

– February 4, 2000: Opening of numbered trust account C-163 under the alias “Jose Velarde”
– October–December 1999 & May–July 2000: Deposits into “Jose Velarde” savings account
– July 12, 2004: Sandiganbayan grants Estrada’s demurrer to evidence in illegal alias case
– April 2, 2009: Supreme Court decision

Applicable Law

– 1987 Constitution (right to be informed of accusation)
– Commonwealth Act No. 142, as amended by R.A. No. 6085 (prohibiting public and habitual use of alias)
– Republic Act No. 1405 (Secrecy of Bank Deposits)
– Republic Act No. 6713 (Code of Conduct and Ethical Standards)
– Republic Act No. 9160 (Anti-Money Laundering Act; prohibiting anonymous/fictitious accounts)
– Ursua v. Court of Appeals (defining “alias” as a name publicly and habitually used in addition to one’s real name)

Facts

Estrada was charged with illegal use of alias for having opened and operated trust account C-163 at PCIB under “Jose Velarde.” Witnesses testified that Estrada signed account documents as “Jose Velarde,” with deposits made into a “Jose Velarde” savings account by Lucena Ortaliza. The People’s evidence centered on bank officers’ testimonies and documents showing the alias use in several transactions.

Proceedings in the Sandiganbayan

– Informations for plunder, illegal use of alias (Crim. Case No. 26565), and perjury were filed and consolidated.
– After the People rested, Estrada moved for leave to file demurrers to evidence.
– On July 12, 2004, the Sandiganbayan granted the demurrer to evidence in the alias case, finding:
• The Information’s phrase “on or about 04 February 2000 or sometime prior or subsequent thereto” limited proof to a single date, precluding multiple habitual uses.
• Lack of publicity: signing in a confidential banking transaction did not demonstrate an intent to be publicly known by the alias.
• Numbered trust accounts were lawful and confidential under R.A. 1405; no obligation existed to disclose the depositor’s chosen name.
• R.A. 9160’s later prohibition against anonymous accounts confirmed that numbered accounts had formerly been legal.

Issues on Appeal

  1. Whether the Sandiganbayan erred in limiting the Information to acts on February 4, 2000.
  2. Whether Estrada’s alias use was public despite confidentiality safeguards.
  3. Whether banking practice justified confidential alias use.
  4. Whether R.A. 1405 and CA 142 should be harmonized to excuse alias use.
  5. Whether Ursua was correctly applied.

Supreme Court’s Analysis

– The Court applied the 1987 Constitution’s right to be informed of the nature and cause of accusation, and Rule 110’s requirements for information. The disjunctive “or” in the Information confined proof to a single date or an approximate alternative, negating multiple habitual uses. Habituality, as defined in Ursua, requires repeated use beyond a single occasion—absent here.
– Publicity requires a manifest intent to be known publicly under the alias. Signing confidential trust-account documents before bank officers and close associates (bound by secrecy) did not demonstrate open or general use.
– R.A. 1405 secures absolute confidentiality of deposits

...continue reading

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.

About Privacy Terms