Primary Holding

The Supreme Court held that Joseph Ejercito Estrada had effectively resigned as President of the Philippines on January 20, 2001, and that Gloria Macapagal-Arroyo had validly assumed the presidency.

Background

Joseph Estrada’s presidency began in 1998 with broad public support but was marred by corruption allegations, including his involvement in illegal gambling operations (jueteng). A series of political and public upheavals culminated in his impeachment trial, which was aborted after senators voted to suppress key evidence. Massive public protests followed, leading to the withdrawal of military and police support for Estrada and the ascension of Vice President Gloria Macapagal-Arroyo.

Facts

• 1. Estrada was implicated in corruption and illegal gambling scandals in late 2000.
• 2. Public and institutional support for Estrada dwindled following Senate refusal to open evidence during the impeachment trial.
• 3. Public protests at EDSA led to calls for Estrada’s resignation.
• 4. Estrada vacated Malacañang on January 20, 2001, after Arroyo’s oath-taking.
• 5. Estrada later argued that he did not resign but was temporarily incapacitated.

Arguments of the Petitioners

• 1. Estrada claimed he did not formally resign but was temporarily unable to perform his duties.
• 2. He argued that criminal investigations against him should be barred as he retained presidential immunity.
• 3. Estrada maintained that Congress, not the Supreme Court, should determine his inability to govern under the Constitution.

Arguments of the Respondents

• 1. Arroyo’s camp argued that Estrada’s actions and public statements indicated a clear resignation.
• 2. Respondents contended that Estrada’s presidency effectively ended with his departure from Malacañang.
• 3. They emphasized the legality of Arroyo’s assumption of office under the Constitution.

Issues

• 1. Did Estrada resign as President?
• 2. Was Arroyo’s assumption of office valid?
• 3. Can Estrada claim immunity from criminal prosecution?
• 4. Does the case present a political question beyond judicial review?

Ruling

• 1. Estrada effectively resigned as President based on his actions, public statements, and the surrounding circumstances.
• 2. Arroyo’s assumption of office was constitutional and valid.
• 3. Estrada no longer enjoyed presidential immunity from prosecution.
• 4. The case presented legal, not political, questions appropriate for judicial review.

Doctrines

• 1. Political Question Doctrine: Limited in scope by the 1987 Constitution, allowing judicial review of issues involving grave abuse of discretion.
• 2. Presidential Immunity: Applies only during the President’s incumbency.
• 3. Resignation Elements: Requires intent and acts demonstrating relinquishment of office.

Precedents Cited

• 1. Baker v. Carr (1962): On political questions and justiciability.
• 2. Tanada v. Cuenco (1957): Defining political questions under Philippine law.
• 3. Marbury v. Madison (1803): Judicial review as the judiciary’s role.

Statutory and Constitutional Provisions

• 1. 1987 Constitution - Section 8, Article VII: Succession to the Presidency.
• 2. 1987 Constitution - Section 11, Article VII: Determination of the President’s inability to govern.
• 3. RA 3019 (Anti-Graft and Corrupt Practices Act): Provisions against resignation during pending investigations.