G.R. No. 146710 -15 & G.R. No. 146738 March 2, 2001
JOSEPH E. ESTRADA, petitioner, vs. ANIANO DESIERTO, et al. and GLORIA MACAPAGAL-ARROYO, respondents.

FACTS

Petitioner Joseph Ejercito Estrada was elected President in May 1998. In October 2000, he was accused by a political ally of receiving millions from illegal gambling. This triggered mass resignations from his cabinet and coalition, widespread public protests, and an impeachment complaint. The House of Representatives transmitted the Articles of Impeachment to the Senate, which commenced trial. On January 20, 2001, the prosecution walked out after the Senate voted against opening an envelope alleged to contain crucial evidence. This precipitated massive street protests.
By January 20, 2001, the Armed Forces and the Philippine National Police withdrew their support from President Estrada. Later that day, Vice President Gloria Macapagal-Arroyo took her oath as President. Estrada later contended he merely left the Palace temporarily and did not resign, claiming he was a President on leave. He filed petitions questioning the authority of the Ombudsman to investigate him for graft and asserting he was still the lawful President, entitled to immunity from suit.

ISSUE

The primary issue is whether Joseph Estrada resigned from the office of the President, thereby making Gloria Macapagal-Arroyo the legitimate President.

RULING

The Supreme Court En Banc ruled that Joseph Estrada resigned from the presidency. The legal logic is rooted in the totality of his acts, omissions, and the surrounding circumstances, which constitute resignation from office. Resignation is a factual question; it can be implied from conduct with a clear intent to relinquish the office, and it need not be in writing. The Court examined key events: the withdrawal of support by the military and police, Estrada’s departure from Malacañang, his public statement wherein he acknowledged the oath-taking of Arroyo and stated he was leaving the Palace for the sake of peace, and the fact that he subsequently negotiated a transition of power. These acts demonstrated a clear surrender, abandonment, and relinquishment of the duties of his office.
The Court further held that with Estrada’s resignation, Gloria Macapagal-Arroyo, as the constitutionally elected Vice-President, was the rightful successor. Consequently, Estrada’s claim to executive immunity was moot. The Court also found no merit in his claim of prejudicial publicity, as he failed to prove actual prejudice. The petitions were dismissed, affirming the legitimacy of the Arroyo presidency.