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    TJ Paula Tapales Jornacion
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    The Supreme Court ruled that the diary of Executive Secretary Angara, who acted as Joseph Estrada's agent in negotiating his resignation, was admissible as evidence against Estrada. As Estrada's alter ego authorized to act on his behalf during the transition of power, statements made by Angara to third parties were considered admissions by Estrada's agent and therefore not barred by the rule against hearsay. The diary provided evidence of Estrada's intent to resign, including proposals that he not run in a snap election and expressions of wanting the transition to be peaceful. As Estrada's agent, Angara's statements and actions were binding on Estrada under the rules of evidence.

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    The Supreme Court ruled that the diary of Executive Secretary Angara, who acted as Joseph Estrada's agent in negotiating his resignation, was admissible as evidence against Estrada. As Estrada's alter ego authorized to act on his behalf during the transition of power, statements made by Angara to third parties were considered admissions by Estrada's agent and therefore not barred by the rule against hearsay. The diary provided evidence of Estrada's intent to resign, including proposals that he not run in a snap election and expressions of wanting the transition to be peaceful. As Estrada's agent, Angara's statements and actions were binding on Estrada under the rules of evidence.

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    24 views2 pages

    Estrada v. Desierto

    Uploaded by

    TJ Paula Tapales Jornacion
    The Supreme Court ruled that the diary of Executive Secretary Angara, who acted as Joseph Estrada's agent in negotiating his resignation, was admissible as evidence against Estrada. As Estrada's alter ego authorized to act on his behalf during the transition of power, statements made by Angara to third parties were considered admissions by Estrada's agent and therefore not barred by the rule against hearsay. The diary provided evidence of Estrada's intent to resign, including proposals that he not run in a snap election and expressions of wanting the transition to be peaceful. As Estrada's agent, Angara's statements and actions were binding on Estrada under the rules of evidence.

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    of 2

    Estrada v.

    Desierto
    G.R. No. 146710-15 | March 2, 2001 and April 3, 2001
    Doctrine: One of the exceptions to the res inter alias acta rule is with respect to admissions by a
    co-partner or agent. Executive Secretary Angara was an alter ego of the former president. Indeed, he was
    authorized by the former president to act for him in the critical hours and days before he abandoned
    Malacanang Palace. Hence, former President Estrada is bound by the acts and declarations of Secretary
    Angara.
    FACTS:
    In the May 11, 1988 elections, Joseph Estrada was elected President while Gloria Macapagal-
    Arroyo was elected Vice-President. From the beginning of his term, Estrada was plagued by a plethora of
    problems that slowly but surely eroded his popularity. Among others, he was accused of receiving
    millions of pesos from jueteng lords. Because of these, calls for his resignation filled the air. An
    impeachment trial ensued against him. By a vote of 11-10, the senator-judges ruled against the opening of
    an envelope which allegedly contained evidence showing that Estrada held P3.3 billion in a secret bank
    account under the name “Jose Velarde.” The ruling was met by a spontaneous outburst of anger that hit
    the streets of the metropolis.
    January 18 saw the high velocity intensification of the call for Estrada’s resignation. A 10-
    kilometer line of people holding lighted candles formed a human chain from the Ninoy Aquino
    Monument on Ayala Ave. in Makati City to the EDSA Shrine to symbolize the people’s solidarity in
    demanding Estrada’s resignation. On January 19, the fall from power of Estrada appeared inevitable.
    High ranking officials have defected their support from Estrada’s administration. This led to the
    resignation of Estrada as President and the assumption of office by Arroyo as the new President of the
    Philippines.
    However, Estrada denied that he resigned as President or that he suffers from a permanent
    disability. Hence, he submits that the office of the President was not vacant when Arroyo took her oath as
    President. In its ruling dated March 2, 2001, the Supreme Court ruled that Estrada resigned as President.
    It held that resignation is a factual question and its elements are beyond quibble: (1) there must be an
    intent to resign and; (2) the intent must be coupled by acts of relinquishment. In ascertaining Estrada’s
    intent to resign, the Supreme Court admitted as evidence against Estrada the diary of Executive Secretary
    Angara serialized in the Philippine Daily Inquirer.
    Said Angara Diary reveals a couple of indicia of his intent to resign. Some of the said indicia are
    as follows: (1) the proposal of Estrada for a snap election for president in May where he would not be a
    candidate; (2) Estrada expressed no objection to the suggestion for a graceful and dignified exit; (3 The
    resignation of Estrada was already implied when Secretary Angara agreed when former President Ramos
    called him up as the former requested the latter to cooperate and to ensure a peaceful and orderly transfer
    of power; and (4) Estrada’s statement saying “Ayoko na masyado nang masakit…” This, according to the
    Supreme Court, is a high grade evidence that Estrada has resigned. “Ayoko na” are words of resignation.
    Thus, in this present action, Estrada contends that the use of Angara Diary against him violated
    the rule on res inter alios acta.
    ISSUE:
    1. Whether the Angara Diary by Executive Secretary Angara is admissible as evidence against
    Estrada? – YES.
    RATIO:
    The res inter alios acta rule has several exceptions. One of them is provided in Sec. 29 (now
    Sec. 30 of the Revised Rules on Evidence) of Rule 130 with respect to admissions by a co-partner or
    agent. Executive Secretary Angara was an alter ego of Estrada. He was the Little President. Indeed, he
    was authorized by Estrada to act for him in the critical hours and days before he abandoned Malacanang
    Palace. Thus, according to the Angara Diary, Estrada told Secretary Angara: “Mula umpisa pa lang ng
    kampanya, Ed, ikaw na lang pinakikinggan ko. At hanggang sa huli, ikaw parin.” This statement of full
    trust was made by Estrada after Secretary Angara briefed him about the progress of the first negotiation of
    the peaceful and orderly transfer of power.
    The Angara Diary also quotes Estrada as saying to Secretary Angara: “Ed, kailangan ko na
    bang umalis?” Secretary Agara told him to go and he did. Estrada cannot deny that Secretary Angara
    headed his team of negotiators that met with the team of Arroyo to discuss the peaceful and orderly
    transfer of power after his relinquishment of the powers of the presidency. Secretary Angara acted for and
    in behalf of Estrada in the crucial days before Arroyo took her oath as President. Consequently, Estrada is
    bound by the acts and declarations of Secretary Angara. Under our rules of evidence, admissions of an
    agent (Secretary Angara) are binding on the principal (Estrada).
    Please Note:
    This digest is a consolidation of two cases entitled “Estrada v. Desierto”. The first case is
    dated March 2, 2001 and the other case is dated April 3, 2001. The former contains the facts and ruling of
    the Supreme Court concerning Estrada’s intent to resign whereas the latter contains the ruling of the
    Supreme Court as regards the application of the principle res inter alios acta.

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