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- President of the Philippines,
has committed the crime of plunder and ordering his prosecution under Republic Act 7080. (An
Act Defining and Penalizing the Crime of Plunder). The petitioner wishes to impress upon us that
the RA 7080 is defectively written, and he then claimed 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
aforementioned law allegedly suffers from vagueness on the terms it uses, particularly:
‘combination’, ‘series’, and ‘unwarranted’. Based on this, the petitioner used the facial challenge Commented [TLQ1]: COMBINATION - At least two (2) acts
(that a government law, rule, regulation, or policy is unconstitutional as written — that is, on its falling under different categories of enumeration provided in
Sec 1
face) to question the validity of RA 7080.
Commented [TLQ2]: SERIES - Two (2) or more overt or
criminal acts falling under the same category of enumeration
found in Sec 1
ISSUES:
WON the Plunder Law is unconstitutional for being vague.

RULING:
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.

ANALYSIS:
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. Commented [TLQ3]: permits a person to challenge a
statute on the ground that it violates the First
A facial challenge is allowed to be made to a vague statute and to one which is overbroad Amendment (free speech) rights of third parties not
before the court, even though the law is constitutional
because of a possible “chilling effect” upon protected speech. as applied to that defendant.
 The overbreadth and vagueness doctrines apply only to free speech cases, but not to
penal statutes.
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 subjects
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.