USA College of Law

AVELINO 1-C

Case Name Estrada v Sandiganbayan

Topic Proper Interpretation of Law
Case No. | Date G.R. No. 148560| November 19, 2001
Ponente Pardo, J.
Petitioner Joseph Ejercito Estrada
Respondent SANDIGANBAYAN (Third Division) and PEOPLE OF THE PHILIPPINES
Void for vagueness – a law which either forbids or requires the doing of an act is created in terms
Doctrine so vague that men of common intelligence must guess its meaning and differ as to its application,
violates the first essential of due process of law.

RELEVANT FACTS
 Estrada was prosecuted for Plunder under RA 7080 (An Act Defining and Penalizing the Crime of Plunder) as
amended by RA 7569.
 He, together with some of his acquaintances, allegedly received billions of pesos from different series or
combination of criminal acts or schemes.
 Estrada claimed the RA 7080 or Plunder Law is unconstitutional because of the following:
o RA 7080 being vague
o It violates rights of the accused to due process.
o Plunder as defined in RA 7080 is a malum prohibitum, and if so, whether it is within the power of
Congress to so classify it.
 Petitioner complained about the RA 7080’s failure to provide for the statutory definition of the terms
"combination" and "series" in the key phrase "a combination or series of overt or criminal acts" found in
Sec. 1, par. (d), and Sec. 2, and the word "pattern" in Sec. 4.
 September 18, 2001 – oral arguments where done for the resolution of the issues aforementioned.

ISSUE: WON Plunder Law is unconstitutional for being vague.

RULING:
NO.

A statute is not void merely because of the employment of general terms or the failure to define the terms used.
The law continues to be valid as long as it provides some comprehensible guide as to what would make those
subject to the said law liable to its penalties.

The doctrine of void-for-vagueness cannot be applied since it an only be used against “a specie of legislation that is
utterly vague on its face”, one which cannot be clarified either by a saving clause or by construction.

Court held that Plunder Law, as amended by RA 7659, is CONSTITUTIONAL.

RULING
Petition to declare the law unconstitutional is DISMISSED for lack of merit.
SEPARATE OPINIONS
(optional)
 USA College of Law
AVELINO 1-C
NOTES
Combination (under Plunder Law)
 it is referring to at least to two acts falling under different categories of enumeration provided in Sec. 1, par.
(d), in Sec. 1, par. (d), subpar. (1) and Sec. 1, par. (d), subpar. (3).

Series
 " there must be two or more overt or criminal acts falling under the same category of enumeration found in
Sec. 1, par. (d), say, misappropriation, malversation and raids on the public treasury, all of which fall under
Sec. 1, par. (d), subpar. (1).