Estrada vs. Sandiganbayan Case Digest

ESTRADA vs. SANDIGANBAYAN CASE DIGEST Estrada vs. Sandiganbayan G.R. No. 148560, November 19, 2001 FACTS: On April 25, 2001, the Sandiganbayan issued a resolution in Criminal Case No. 26558, finding probable cause that petitioner Joseph Ejercito Estrada, then the President of the Philippines has committed the offense of plunder, and that he be prosecuted under RA 7080 (An Act Defining and Penalizing the Crime of Plunder). The petitioner contended that RA 7080 was unconstitutional, on the grounds that 1.) it was vague; 2.) it dispenses with the “reasonable doubt” standard in criminal prosecutions; and 3.) it abolishes the element of mens rea in crimes already punishable under The Revised Penal Code, thus violating the fundamental rights of the accused. The said law allegedly suffers from vagueness on the terms it uses, particularly: ‘combination’, ‘series’, and ‘unwarranted’. Based on this, the petitioner used the facial challenge to question the validity of RA 7080. ISSUES: 1. WON the Plunder Law is unconstitutional for being vague. 2. WON the fact that the Plunder Law requires less evidence for proving the predicate crimes of plunder leads to its violation of the right of the accused to due process. 3. WON Plunder as defined in RA 7080 is a malum prohibitum, and if so, whether it is within the power of Congress to classify it as such. RULE: The void-for-vagueness doctrine states that a statute which either forbids or requires the doing of an act in terms so vague that men of common intelligence must necessarily guess at its meaning and differ as to its application, violates the first essential of due process of law. The over-breadth doctrine states that a governmental purpose may not be achieved by means which sweep unnecessarily broadly and thereby invade the area of protected freedoms. A facial challenge is allowed to be made to a vague statute and to one which is overbroad because of a possible “chilling effect” upon protected speech. This rationale does NOT apply to penal statutes. ANALYSIS: 1. NO. A statute is not rendered uncertain and void merely because of the employment of general terms or the failure to define the terms used therein. The validity of a law is sustained, so long as that law provides some comprehensible guide as to what would render those subject to the said law liable to its penalties. The petitioner cannot rely on the void-for-vagueness doctrine, since this doctrine does not apply to laws that merely consist of imprecise language. 2. NO. The Bill of Rights guarantees the right of the accused in criminal prosecutions to be presumed innocent until proven otherwise. Thus he is entitled to an acquittal unless the State succeeds in demonstrating the guilt of the accused with proof beyond reasonable doubt. The contention that Sec. 4 of RA 7080 does away with proof of each and every component of the crime is a misconception. Rather than proving each and every criminal act done, it is enough that the prosecution proves beyond reasonable doubt a pattern of overt or criminal acts indicative of the crime as a whole. 3. NO. Plunder is a malum in se which requires proof of criminal intent. The legislative declaration in RA No. 7659 (which has been declared as constitutionally valid in a previous ruling) that plunder is a heinous offense implies that it is a malum in se. CONCLUSION: Premises considered, the Court holds that RA 7080 otherwise known as the Plunder Law, as amended by RA 7659, is CONSTITUTIONAL. Thus, the petition to declare the law unconstitutional is DISMISSED for lack of merit.