G.R. No. 148560 ; November 19, 2001
JOSEPH EJERCITO ESTRADA, petitioner, vs. SANDIGANBAYAN (Third Division) and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Joseph Ejercito Estrada, the former President of the Philippines, was charged before the Sandiganbayan with the crime of plunder under Republic Act No. 7080 , as amended. The Office of the Ombudsman filed an Information alleging that he amassed ill-gotten wealth in the aggregate amount of over Four Billion Pesos through a combination or series of overt criminal acts. Prior to his arraignment, Estrada filed a motion for bill of particulars and to quash the Information, challenging the constitutionality of the Plunder Law itself. The Sandiganbayan denied his motions.
Estrada filed a petition for certiorari before the Supreme Court, assailing the Sandiganbayan’s resolutions. He argued that RA 7080 is unconstitutional for being void for vagueness, as it allegedly fails to define the crime with sufficient definiteness. He also contended that the law dispenses with the reasonable doubt standard and abolishes the element of mens rea for crimes already punishable under the Revised Penal Code, thereby violating the constitutional rights of the accused to due process and to be informed of the nature of the accusation.

ISSUE

Whether Republic Act No. 7080 (The Plunder Law) is unconstitutional for being void for vagueness and for allegedly violating the constitutional rights of the accused to due process.

RULING

The Supreme Court dismissed the petition and upheld the constitutionality of the Plunder Law. The Court ruled that the law is not void for vagueness. The statute defines the crime with sufficient clarity and provides ascertainable standards for its enforcement. The term “combination or series of overt or criminal acts” is not vague, as it simply enumerates the different modes of committing plunder, which are themselves specific acts defined under existing penal statutes. The law provides a detailed definition of “ill-gotten wealth” and enumerates the specific means by which it can be amassed, thereby giving a person of ordinary intelligence fair notice of what is prohibited.
The Court further held that the law does not dispense with the reasonable doubt standard. Section 4 of RA 7080, which states that it is not necessary to prove each and every criminal act to establish plunder, merely provides a rule of evidence for prosecuting a complex crime of large scale. It does not lower the quantum of proof required, which remains proof beyond reasonable doubt of the overall conspiracy or scheme to amass ill-gotten wealth. The law also does not abolish mens rea. The elements of knowledge and intent are presumed from the commission of the predicate acts themselves, which are malum in se. The legislative intent is to treat plunder as a malum prohibitum for purposes of imposing severe penalties on large-scale corruption, which is a valid exercise of police power. The petition was dismissed for lack of merit.