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Estrada VS Sandiganbayan

The Supreme Court upheld the constitutionality of the Anti-Plunder Law (RA 7080) in the case of Estrada vs. Sandiganbayan. President Joseph Estrada claimed the law was unconstitutional because it was vague and abolished the requirement of criminal intent. However, the Court found that the law clearly expressed the legislative intent through the plain meaning of its language. Additionally, it ruled the crime of plunder was mala in se and required proof of criminal intent, as the information specified Estrada committed the theft of P4 billion from the people "willfully, unlawfully and criminally."

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Debroah Faith Pajarillo
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51 views2 pages

Estrada VS Sandiganbayan

The Supreme Court upheld the constitutionality of the Anti-Plunder Law (RA 7080) in the case of Estrada vs. Sandiganbayan. President Joseph Estrada claimed the law was unconstitutional because it was vague and abolished the requirement of criminal intent. However, the Court found that the law clearly expressed the legislative intent through the plain meaning of its language. Additionally, it ruled the crime of plunder was mala in se and required proof of criminal intent, as the information specified Estrada committed the theft of P4 billion from the people "willfully, unlawfully and criminally."

Uploaded by

Debroah Faith Pajarillo
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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ESTRADA VS SANDIGANBAYAN

Facts: The Court has found President ERAP, with family


and associates, GUILTY of plunder amounting to P4B
under the account name ‘Jose Velarde’. Here, ERAP
seeks to petition that (1) RA 7080 (Anti-Plunder Law) is so
vague, it’s unconstitutional. (2) Also, due to the
vagueness, he must be acquitted due to “reasonable
doubt” and (c) the law, in effect, abolishes the requirement
of mens rea to crimes already punishable under the RPC.

Issue: Whether or not RA 7080 is UNCONSTITUTIONAL


due to:
• Vagueness
• Abolishing the Mens Rea requirement through the
conversion of the crime from mala inse to mala
prohibitum

Held: ALL UNTENABLE. The Court held that RA 7080 is


constitutional.

Ratio:
(1) Law is not vague. Any purported inability of
Congress to clearly define the words employed will NOT
necessarily void the law for vagueness SO LONG AS the
legislative will is clear, or at least can be gathered from the
whole act. RA 7080 distinctly expressed it’s legislative will.
Moreover, legal hermeneutics provide that words in a
statute shall be interpreted in their plain and ordinary
meaning since Congress are also regular people, unless
the law itself indicates a special legal meaning. Here,
when the Anti-Plunder Law used the words “combination"
and "series", it simply means combination and series. For
just as the accused is entitled to the presumption of
innocence in the absence of proof beyond reasonable
doubt, so must a law be accorded the presumption of
constitutionality without the same requisite quantum of
proof. "The constitutionality of laws is presumed. To justify
nullification of a law, there must be a clear and
unequivocal breach of the Constitution, not a doubtful or
argumentative implication; a law shall not be declared
invalid unless the conflict with the Constitution is clear
beyond a reasonable doubt. 'The presumption is always in
favor of constitutionality . . . To doubt is to sustain.' The
"vagueness" doctrine merely requires a reasonable
degree of certainty— not absolute precision or
mathematical exactitude, as ERAP seems to suggest.
(2) Mens Rea. The majority agreed with Justice
Mendoza who stated that Plunder is mala inse. Precisely,
his constitutive crimes (series or combinations of acts)
must be proven. Here, the information stated that the
crime was committed “willfully, unlawfully and criminally”,
thus alleging guilty knowledge of the petitioner. Clearly,
the stealing of P4B from the people must be treated with
the same gravity as arson, murder, etc and not as lightly
as BP 22 offenses and jaywalking, which are mala
prohibita crimes.

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