Former President Joseph

Estrada was Never Impeached

from His Position
Introduction

Joseph Ejercito was born on April 19, 1937 in Manila, Philippines. He is a

Filipino actor and politician who served as President of the Philippines from
1998 to 2001. Estrada entered politics in 1968, successfully running for mayor
of the Manila suburb of San Juan, a position he held until 1986. He was elected
to the Senate in 1969. He ran for vice president on the National People's
Coalition ticket in 1992.
In 1998, Joseph Ejercito Estrada was elected President of the Philippines
with 10,722,295 votes. Estrada was elected President with the most votes cast
in Philippine history. Gloria Macapagal-Arroyo, on the other hand, was elected
Vice President in the same election, with more votes than Estrada.
The Philippine Senate began an impeachment trial in November, but it
was called off after some senators objected to the admission of evidence.
On January 20, 2001, Estrada was deposed amid widespread protests,
and his vice president, Gloria Macapagal Arroyo, took over as president.
This mini-research study will look at the Court's reasoning in deciding the
issue of President Estrada's resignation in light of the facts and
circumstances of the case, as well as the prevailing law on the subject.
Despite the Court's decisions on other issues, the issue of resignation was
the lis mota of the controversy, on which the other issues were
depended.
REASONS OF IMPEACHMENT

The complaint for impeachment is based on the following

grounds:
I. THAT RESPONDENT COMMITTED BRIBERY;
II. THAT RESPONDENT COMMITTED GRAFT AND CORRUPT
PRACTICES;
III. THAT RESPONDENT BETRAYED THE PUBLIC TRUST;
IV. THAT RESPONDENT CULPABLY VIOLATED THE
CONSTITUTION.
I. That respondent committed bribery.

Complainants accuse respondent of committing

Bribery committed as follows:
"That from November 1998 to August 2000, respondent
has received P10 million a month as bribery from
jueteng lords as protection money channeled through
Luis C. Singson, provincial governor of Ilocos Sur as may
be seen from his affidavit dated September 14, 2000
(Annex "A" hereof)."
II. That respondent committed graft and corrupt practices.

• President Joseph E. Estrada violated the Constitution and stands guilty of graft and
corruption when he directly requested or received for his personal benefit P130 million
out of the P200 million released by Secretary Benjamin Diokno of the Department of
Budget and Management.
• President Joseph E. Estrada violated the Constitution and stands guilty of graft and
corruption when he participated directly in the real estate business thru family-
controlled corporation which constructed 36 townhouses in Vermont Park, Executive
Village, Antipolo City.
• He also violated the Anti-Graft Law he is sworn to uphold. He filed his Statement of
Assets and Liabilities for the year 1999, stating therein that he and his wife and children
have business interests in only three (3) corporations. The President by that sworn
statement also committed perjury and the offense of unexplained wealth because
records show that he and his wife and mistresses and their children have other
interests in other companies outside of the firms listed in his Statement of Assets and
III. That respondent betrayed the public trust.

• President Joseph E. Estrada betrayed public trust and violated his own
oath of office when he unduly intervened in the Securities and
Exchange Commission on behalf of a presidential crony.
• President Estrada betrayed public trust when he wantonly violated his
official pronouncement during his inaugural speech, when he solemnly
declared, "sa aking administrasyon, walang kamag-anak, walang
kumpadre, walang kaibigan."
• President Estrada betrayed the public trust and his oath of office when
he disobeyed the strict mandate of the Constitution that he sternly
avoid conflict of interest in the conduct of his office.
IV. That respondent culpably violated the Constitution.

• President Estrada violated the law and his own oath of office
when he ordered the Commissioner of Customs to turn over 52
luxury vehicles to Malacañang for distribution to Cabinet
members and other senior officials to give them more prestige
and financial help.
• President Estrada willfully violated the Constitution when he
appointed certain members of his Cabinet, their deputies or
assistants to another office or employment in direct
contravention of Section 13, Article VII of the Constitution.
IMPEACHMENT TRIAL OF ESTRADA

• 23 Length in days of then President Joseph Estrada’s impeachment trial. The trial
started on Dec. 7, 2000, and ended on Jan. 16, 2001.
• 11 Number of prosecutors led by then House Minority Leader Feliciano
Belmonte Jr.
• 6 Members of the defense team headed by former Chief Justice Andres Narvasa.
• 22 Number of senator-judges.
• 30+ Number of witnesses presented during the impeachment trial.
• 4 Number of grounds for impeachment against Estrada. They were bribery, graft
and corruption, betrayal of public trust and culpable violation of the
Constitution.
• P10 M Amount allegedly received monthly by Estrada from November 1998 to
August 2000 from “jueteng” lords as protection money, according to the
impeachment complaint.
• P130 M Amount of kickbacks allegedly given to Estrada from the P200 million
released by then Budget Secretary Benjamin Diokno for tobacco farmers.
• P100 M Amount of donation from government funds allegedly received by a
private organization organized by Estrada’s wife.
• 52 Number of impounded luxury vehicles that Estrada allegedly ordered the
customs commissioner to turn over to Malacañang for distribution to Cabinet
secretaries and other senior officials.
 Prejudicial Publicity on the Court

Petitioner insists he is the victim of prejudicial publicity. Among

others, he assails the Decision for adverting to newspaper accounts of
the events and occurrences to reach the conclusion that he has
resigned. In our Decision, we used the totality test to arrive at the
conclusion that petitioner has resigned. We referred to and analyzed
events that were prior, contemporaneous and posterior to the oath-
taking of respondent Arroyo as president. All these events are facts
which are well-established and cannot be refuted. Thus, we adverted to
prior events that built up the irresistible pressure for the petitioner to
resign.
These are:
• (1) the exposé of Governor Luis "Chavit" Singson on October 4, 2000;
• (2) the "I accuse" speech of then Senator Teofisto Guingona in the Senate;
• (3) the joint investigation of the speech of Senator Guingona by the BlueRibbon Committee
and the Committee on Justice;
• (4) the investigation of the Singson exposé by the House Committee on Public Order and
Security;
• (5) the move to impeach the petitioner in the House of Representatives;
• (6) the Pastoral Letter of Archbishop Jaime Cardinal Sin demanding petitioner’s resignation;
• (7) a similar demand by the Catholic Bishops Conference;
• (8) the similar demands for petitioner’s resignation by former Presidents Corazon C. Aquino
and Fidel V. Ramos;
• (9) the resignation of respondent Arroyo as Secretary of the DSWD and her call for petitioner to resign;
• (10) the resignation of the members of petitioner’s Council of Senior Economic Advisers and of Secretary
Mar Roxas III from the Department of Trade and Industry;
• (11) the defection of then Senate President Franklin Drilon and then Speaker of the House of
Representatives Manuel Villar and forty-seven (47) representatives from petitioner’s LapiangMasang
Pilipino;
• (12) the transmission of the Articles of Impeachment by Speaker Villar to the Senate;
• (13) the unseating of Senator Drilon as Senate President and of Representative Villar as Speaker of the
House;
• (14) the impeachment trial of the petitioner;
• (15) the testimonies of Clarissa Ocampo and former Finance Secretary Edgardo Espiritu in the
impeachment trial;
• (16) the 11-10 vote of the senator-judges denying the prosecutor’s motion to open the 2nd envelope
which allegedly contained evidence showing that petitioner held a P3.3 billion deposit in a secret bank
account under the name "Jose Velarde" ;
• (17) the prosecutors’ walkout and resignation;
• (18) the indefinite postponement of the impeachment proceedings to give a chance to the House of
Representatives to resolve the issue of resignation of their prosecutors;
• (19) the rally in the EDSA Shrine and its intensification in various parts of the country;
• (20) the withdrawal of support of then Secretary of National Defense Orlando Mercadoand the then
Chief-of-Staff General Angelo Reyes together with the chiefs of all the armed services;
• (21) the same withdrawal of support made by the then Director General of the PNP; General Panfilo
Lacson, and the major service commanders;
• (22) the stream of resignations by Cabinet secretaries, undersecretaries, assistant secretaries and bureau
chiefs;
• (23) petitioner’s agreement to hold a snap election and opening of the controversial second envelope. All
these prior events are facts which are within judicial notice by this Court. There was no need to cite their
news accounts. The reference by the Court to certain newspapers reporting them as they happened does
not make them inadmissible evidence for being hearsay. The news account only buttressed these facts as
facts. For all his loud protestations, petitioner has not singled out any of these facts as false.
THE ABORTED TRIAL

• The evening of January 16, 2001 was perhaps the most crucial event that transpired in the
short-lived impeachment trial.
• The prosecution requested that a second envelope of documents from Equitable-PCI Bank
which were said to have contained damning evidence which would further link Estrada to the
Jose Velarde account, allegedly containing PhP 3.3 Billion.
• December 7, impeachment proceedings were begun in the Senate during which more serious
allegations of graft and corruption against petitioner were made and were only stopped on
January 16, 2001 when 11 senators, sympathetic to petitioner, succeeded in suppressing
damaging evidence against petitioner. As a result, the impeachment trial was thrown into an
uproar as the entire prosecution panel walked out and Senate President Aquilino Pimentel
resigned after casting his vote against petitioner.
• Because 11 out of 21 senators vote to not open the envelope that contains the evidence, all of
the prosecution panel and even Senate President Pimentel resigned after casting their votes.
• The next day, the Impeachment Court received a letter from the private prosecutors,
informing the Court of their withdrawal from the impeachment case. Senator Raul Roco
moved to adjourn the trial indefinitely until the House of Representatives have selected a
new panel of prosecutors. The trial is adjourned indefinitely over the plea of the defense to
be heard.
• There are 3 primary sources why the case of President Estrada is being aborted. The Angara
Diary Rules on evidence Misappreciation of Facts.
• Senator Angara was a former executive secretary of President Estrada. They say that the
diary was an authoritative window on the state of mind of the President to assume the
power that is not granted by the Law.
• The Angara Diary is called Hearsay. Its said that the competency and credibility of some
persons other than the witness by whom it sought to produce. It is primordial rule that
hearsay evidence is inadmissible except when such evidence falls under certain exceptions.
• The basis for this evidence is that the fact that is not subject to the tests which can ordinarily
be applied for the truth of testimony since the declarant is not present and available for cross
examination.
• In April 2001 the court contented the diary was an exception for hearsay rule as it contained
direct statement of Estrada. The problem with the Courts reasoning is that the fact that it is
not sworn of testimony of a witness but in a journal reprinted in a news article.
• Since the Court had decided to act as a trier of facts in Estrada’s case, when as a rule it only
resolves questions of law and does not entertain questions of facts, 130 then it should have
ensured that the evidence it was relying on were admissible. The least it could have done was
to summon Angara to personally appear before the Court and, under oath, attest to the truth
of the contents of his diary
• For the second primary source the Court decided to cite certain excerpts from the diary to
support its findings that there was resignation. When the President call for a snap election
they did not get the main reason why President called for it. The court already assumed that
the President did it to give up his presidency. They did not consider the main reason of the
President
• Because of the Presidents suggestion to gracefully exit in his job, the Court really
assumed that it was the proof of reality that the President has to resign.
• The Court said that at this point, Estrada was already concerned with the five-day grace
period he could stay in the Palace. 138 On the contrary, there was no mention by
Estrada that he was to resign in five days. Moreover, when the President said, “Pagod na
pagod na ako. Ayoko na, masyado nang masakit. Pagod na ako sa red tape, bureaucracy,
intriga. (I am very tired. I don’t want any more of this – it’s too painful. I’m tired of the
red tape, the bureaucracy, the intrigue.) I just want to clear my name, then I will go,”
• The Court states that this statement by the President was high-grade evidence that he
had resigned.
• But then again there is no such statement to prove that the President had resign but
voluntarily sacrifice his position to have peace in our country
• He may felt exhausted end exasperated about the situation but he never said he would resign.
• Why the Court would describe such a vague and equivocal statement, and from a newspaper
source at that, as “high-grade evidence” is beyond the authors.
• And last the third primary source is the Res Inter AliosActa Doctrine. At this point the Court said
that the resignation was implied but the fact the it was not Estrada who agreed with it but a
transfer of power to Angara is not acceptable except if it is provided or by the Rules of Court.
• A contract made by other people cannot affect the rights of a non-party.
• The Court argues that Angaras Act of agreeing to the suggestion of President Ramos was an
exception to the Rule 130 section 29.
• Even if Angara agreed on the transfer of power the Rule of the Court is that even if the contract
was made by others it doesn't mean that it will affects the right of the President.
• That means that upon agreeing in the resignation, has no connection to the President.
• In President Estradas case, no other evidence was relied upon by the
court except the declaration of Angaras Diary.
• It said that the agency must be proved another source and not by the
declaration itself.
• The declarations of the alleged agent are not competent to prove the
existence of the relation of the principal and agent although they are
accompanied by acts purporting to be acts of agency.
• Though it is granted that the Executive Secretary may be considered an
“agent” under the theory of qualified political agency, the powers
exercisable by the declaration itself.
• Executive Secretary pertains to the executive power conferred in the President by
the Constitution and by law.
• The act of resignation by a President is a personal act, in the same vein that the
assumption to office by a President is a personal act. Thus, even if Angara was
acting as an ordinary agent during the negotiations, he could not resign the
President either directly or by declaration.
• Even if Angara is one of his agents he don’t have the rights to declare resignation of
his President even if the act is personally connected to the President
• Even if Angara was acting as an agent in the civil law sense, his act of agreeing to
terms and conditions set by the opposition would not be binding upon Estrada.
This is simply because the act of resignation is a purely personal act, and cannot be
delegated or effected by a person in behalf of another.
• Angara has acted beyond the scope of his authority
• Moreover, even assuming that Angara had been acting as President Estrada’s agent
within the contemplation of the admission by agent exception, President Estrada
would still not be bound by Angara’s admissions on resignation,
• When General Reyes notified Angara that the Supreme Court had decided to
administer the oath on Gloria Macapagal-Arroyo as President, the conditions
precedent for the proposed resignation never came to be and were never agreed
upon.
• Afterwards Angara instructed to delete the provision on resignation in the agreement
and in that case it was the evidence that no resignation took place
• Thus, the Court, in using the Angara diary, violated not only rudimentary rules and
principles on evidence, but grossly misinterpreted the contents of the diary itself.
Analyzing the Decision: Uncovering the Mysticism

• According to the Constitution of 1987, a vacancy in the Office of the President can
be established only in the following four circumstances: death, permanent
disability, removal from office, or resignation from office. Removal from office is
by impeachment, the only mode of removal of the President sanctioned by the
Constitution. 211 Permanent disability involves a physical or mental condition or
illness which permanently incapacitates the President from discharging his
functions as President. Resignation involves a formal notification of relinquishing
office or position. The vacancy created in these situations is a permanent vacancy.

• In the case of Former President Joseph Estrada, the Supreme Court held that a
vacancy occurred as a result of his RESIGNATION.
WHAT IS RESIGNATION?

• Resignation is defined in the United States as the formal renunciation or

relinquishment of a public office.
• A formal notification of relinquishing an office or position is referred to as
resigning.
• According to Philippine law, there must be an intention to relinquish a portion of
the term, followed by the act of relinquishment, to constitute a complete and
operative resignation of public office.
• Resignation entails the incumbent's express or implied indication of intent to
surrender, renounce, and relinquish his rights to the office, as well as its
acceptance by competent and lawful authority. Except if the law expressly states
otherwise, resignation may be achieved by any way that is suggestive of intent.
• In general, it does not have to be in writing; it might
be oral or implied by behavior.
• A resignation, however, must be done voluntarily in
order to be valid and effective.
• The resignation may be revoked if it was obtained
through fraud or duress.
 WHAT THE COURT CONSIDERED?

Relying heavily on a diary published in a newspaper, a press

statement issued after the Macapagal-Arroyo oath taking took
place, and the departure of the Estrada family from Malacañang
Palace after the said oath taking, the Court concluded that
President Estrada had resigned. The following are what the court
considered:
1. The Angara Diary
2. Rules on Evidence
3. Misappreciation of Facts
Although the Court did not treat the issued press statement as
President Estrada’s resignation letter, it held that the
statement was proof of his resignation. The Court ruled that
President Estrada’s press statement and his family’s departure
from the Palace on the afternoon of January 20, 2001
confirmed his resignation from office and these were overt
acts which leave no doubt that Estrada had resigned. This is
yet another flawed conclusion by the Court.
In his Omnibus Motion, President Estrada asserted that it was
fear of bloodshed and the safety of his person and family that
made him decide to leave the Palace. He also explained that
the statement he had issued was a call for sobriety in the face
of clear and present danger from a threatening mob outside
the Palace. It was not an act of relinquishing the presidency.
Before leaving the Palace, President Estrada had written the
following press statement:
 A copy of the letter was sent to House of
Representatives Speaker Fuentebella at 8:30 a.m., on
January 20. Another copy was transmitted to Senate
President Pimentel on the same day although it was
received only at 9:00 p.m
WHAT THE COURT DID NOT CONSIDER?

1. The Angara Affidavit

2. Ignoring the Estrada Letter
3. No Permanent Disability
The Angara Affidavit

• The Court failed to consider Senator Angara's affidavit, in which he said

categorically that he never stated or intimated in his diary that
President Estrada had resigned. The Angara affidavit was presented to
the Court as part of President Estrada's Omnibus Motion. Angara
clarified in his affidavit that no resignation ever took place.
• The omnibus motion rule embodied in Rule 15, Section 8, of the Rules
of Court reads as follows:
Sec. 8. Omnibus motion. — A motion attacking a pleading or a
proceeding shall include all objections then available, and all
objections not so included shall be deemed waived.
 In the absence of agreement on the conditions to the
planned resignation, President Estrada never resigned.
Furthermore, the evidence dispels any assumption that Angara had
written in his diary declaring that Estrada had resigned. It's
interesting to notice that the Court never cited the author's
affidavit, which was the foundation of the ruling. If the Court
trusted an unsworn diary published in a newspaper, it should have
given the sworn statement of the author even more weight and
value as evidence. The Court, on the other hand, treated the
affidavit as if it didn't exist.
Ignoring the Estrada Letter

President Estrada alleges that he had never resigned as President but is

temporarily unable to act as President. Pursuant to Article VII, Section 11 of the
Constitution he wrote a letter declaring his temporary incapacity and sent identical
copies to both chambers of Congress.
The letter was described by the Court as "wrapped in mystery." The letter was not
taken into consideration by the court because Estrada refused to address the events that
led to its creation and because he made no mention of it in his final press release. The
Court further argued: “Under any circumstance, however, the mysterious letter cannot
negate the resignation of the petitioner. If it was prepared before the press release of
the petitioner (Estrada) clearly showing his resignation from the presidency, then the
resignation must prevail as the later act. If, however, it was prepared after the press
release, still it commands scant legal significance. Petitioner’s (Estrada’s) resignation
from the presidency cannot be subject to a changing caprice nor of a whimsical will
especially if the resignation is the result of his repudiation by the people.”
 This Court's decision is disturbing, to say the least. Just why are letters
and press releases treated so differently? Why should the press statement have
greater legal weight and significance than the letter, which was an official act of
the executive, a department with the same status as the court? In the same
manner that the press statement never mentioned the existence of the letter
sent to Congress, it never mentioned any act of resignation. The letter, on the
other hand, stated clearly and unequivocally the fact that the President was
temporarily unable to act as President. According to the Constitution, the letter
was sent to both houses of Congress and received by the Senate President and
the Speaker of the House. The Court refused to consider the letters, claiming
that President Estrada never mentioned their existence or preparation.
• When the Speaker of the House and the President of the Senate both
acknowledged receipt of the letter, why did the Court refuse to accept its
existence?
By stating that the letter is "wrapped in mystery,"
• Was the Court implying that it didn't exist or that it was uncertain?
Both houses of Congress have copies of the letter in their possession, thus
it's a fact. Even though President Estrada had not mentioned its existence or
preparation, the letters are open to the general public. Letters are official acts of
the Philippine executive department and must be given mandatory judicial
notice in the Philippines. President Estrada was therefore not bound to prove the
letter’s existence to the Court.
• Was the Court under the idea that Estrada had resigned as
President and the letter was not an official act of the executive?
Because President Estrada was still in office when he sent the
letter, even if he had resigned, the letter would still constitute an
official act of the Executive. Because the press release served as
proof of resignation, the Supreme Court ruled that the letter was
an official executive act subject to required judicial notice
because it was written prior to the public announcement.
 No Permanent Disability
• President Estrada was clearly in no condition to assume his duties as President. He experienced
a psychologically traumatizing event in his life during the weeklong crisis that lead to Arroyo’s
oath taking. He was within his rights to take a leave, so to speak, in order to collect himself. His
experience did not leave him permanently disabled, physically or mentally, as evidenced by his
filing of a petition to question Arroyo’s assumption to office.
• This statement by Congress cannot be considered as a ground for declaring the permanent
disability of the President, precisely because it is only through an election that “the people’s”
confidence in a person’s ability to effectively govern is determined. Whether or not “the
people” have lost confidence in an elected official is precisely a political question that can only
be answered through an election. It involves a question which, under the Constitution, is to be
decided by the people in their sovereign capacity. In the absence of an election, therefore,
neither Congress, the Commission on Elections, 233 nor the Supreme Court is empowered to
ascertain whether or not the people have lost confidence in any elective official.
Conclusion

• For the reasons given in my concurring opinion in these cases, I am of the opinion that, having lost the public
trust and the support of his own cabinet, the military and the national police, petitioner Joseph Ejercito
Estrada became permanently disabled from continuing as President of the Philippines and that respondent
Gloria Macapagal-Arroyo, being then the Vice-President, legally succeeded to the presidency pursuant to Art.
VII, 8 of the Constitution.
• My concern in this separate opinion is with petitioner’s claim in G.R. Nos. 146710-15 that he must be deemed
acquitted of the charges against him because the Senate impeachment proceedings against him were
terminated not at his instance, and, consequently, he cannot be prosecuted again for the same offense(s)
without violating his right not to be placed in double jeopardy.
• Petitioner cites Art. XI, 3(7) of the Constitution which provides that —
Judgment in cases of impeachment shall not extend further than removal from office and disqualification to
hold any office under the Republic of the Philippines, but the party convicted shall nevertheless be liable and
subject to prosecution, trial and punishment according to law.
• Petitioner argues that the purpose of the provision allowing subsequent prosecution and trial of a party
convicted in an impeachment trial is precisely to preclude a plea of double jeopardy by the accused in the
event he is convicted in the impeachment trial.
• Petitioner’s contention cannot be sustained. In the first place, the impeachment proceedings against petitioner were
terminated for being functus officio, since the primary purpose of impeachment is the removal of the respondent therein
from office and his disqualification to hold any other office under the government.
• In the second place, the proviso that an impeached and convicted public official would "nevertheless" be subject to
criminal prosecution serves to qualify the clause that "judgment in cases of impeachment shall not extend further than
removal from office and disqualification to hold any office under the Republic of the Philippines." In other words, the
public official convicted in an impeachment trial is nevertheless subject to criminal prosecution because the penalty which
can be meted out on him cannot exceed removal from office and disqualification to hold office in the future. Consequently,
where as in this case, the impeachment proceedings did not result in petitioner’s conviction, there can be no objection to
his subsequent trial and conviction in a criminal case. The rule that an impeachable officer cannot be criminally prosecuted
for the same offenses which constitute grounds for impeachment presupposes his continuance in office. 1 As Professor
Tribe has written:chanrob1es virtual 1aw library

. . . [I]t should also be possible for an official to be acquitted by the Senate in an impeachment trial but subsequently
convicted of the same underlying acts in a federal court. The Senate’s acquittal, after all, could well represent a
determination merely that the charged offenses were not impeachable, or that the nation would be harmed more than
protected by pronouncing the official guilty.
• Hence, the moment he is no longer in office because of his removal,
resignation, or permanent disability, there can be no bar to his criminal
prosecution in the courts.
• Indeed, tested by the ordinary rules of criminal procedure, since
petitioner was neither convicted nor acquitted in the impeachment
proceedings, nor the case against him dismissed without his consent, his
prosecution in the Sandiganbayan for the same offense for which he was
impeached cannot be barred.
• For these reasons, I concur in the denial of the motions for
reconsideration filed on behalf of petitioner in these cases.
 References:

Britannica, T. Editors of Encyclopaedia (2021, April 15). Joseph Estrada. Encyclopedia Britannica. https://
www.britannica.com/biography/Joseph-Estrada

Chan, J. G., Managing Partner, Robles, C., & Associates Law Firm. (n.d.). Impeachment complaint against president Joseph ejercito Estrada - Chan
Robles virtual law library. Chanrobles.Com. Retrieved September 19, 2021, from https://chanrobles.com/legal11impeachmentcomplaint.htm

Inquirer, P. D. (2012, January 16). Fast facts: Estrada impeachment trial. Inquirer.Net. https://
newsinfo.inquirer.net/128607/fast-facts-estrada-impeachment-trial

ReD. (n.d.). G.R. Nos. 146710-15 & 146738 April 3, 2001 - JOSEPH E. ESTRADA v. ANIANO DESIERTO, ET AL. : April 2001 - Philipppine Supreme Court
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(N.d.-b). Upenn.Edu. Retrieved September 19, 2021, from https://

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RonaldEchalasDiaz-CTO. (n.d.). G.R. Nos. 146710-15 and 146738 April 3, 2001 - JOSEPH E. ESTRADA v. ANIANO DESIERTO, ET AL. Chanrobles.Com.
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