BASIC FACTS

On 4 April 2001, an Information for plunder was filed

against former President Joseph Ejercito Estrada,
together with Jose Jinggoy Estrada, Charlie Atong
Ang, Edward Serapio, Yolanda T. Ricaforte, Alma
Alfaro, Eleuterio Tan, a.k.a. Eleuterio Ramos Tan or Mr.
Uy, Jane Doe a.k.a. Delia Rajas, and John & Jane Does,
for the crime of Plunder defined and penalized
under R.A. No. 7080, as amended by Sec. 12 of R.A.
No. 7659. The Information was subsequently amended,
as follows:
AMENDED INFORMATION
The undersigned Ombudsman Prosecutor and OICDirector, EPIB, Office of the Ombudsman, hereby
accuses former PRESIDENT OF THE PHILIPPINES,
Joseph Ejercito Estrada a.k.a. ASIONG SALONGA AND
a.k.a. JOSE VELARDE, together with Jose Jinggoy
Estrada, Charlie Atong Ang, Edward Serapio,
Yolanda T. Ricaforte, Alma Alfaro, JOHN DOE a.k.a.
Eleuterio Tan OR Eleuterio Ramos Tan or Mr. Uy, Jane
Doe a.k.a. Delia Rajas, and John DOES & Jane Does,
of the crime of Plunder, defined and penalized under
R.A. No. 7080, as amended by Sec. 12 of R.A. No. 7659,
committed as follows:
That during the period from June, 1998 to January,
2001, in the Philippines, and within the jurisdiction of
this Honorable Court, accused Joseph Ejercito Estrada,
THEN A PUBLIC OFFICER, BEING THEN THE
PRESIDENT OF THE REPUBLIC OF THE
PHILIPPINES,
by
himself
AND/OR
in
CONNIVANCE/CONSPIRACY with his co-accused,
WHO ARE MEMBERS OF HIS FAMILY, RELATIVES
BY AFFINITY OR CONSANGUINITY, BUSINESS
ASSOCIATES, SUBORDINATES AND/OR OTHER
PERSONS, BY TAKING UNDUE ADVANTAGE OF HIS
OFFICIAL POSITION, AUTHORITY, RELATIONSHIP,
CONNECTION, OR INFLUENCE, did then and there
willfully, unlawfully and criminally amass, accumulate
and acquire BY HIMSELF, DIRECTLY OR
INDIRECTLY, ill-gotten wealth in the aggregate amount
OR TOTAL VALUE of FOUR BILLION NINETY SEVEN
MILLION EIGHT HUNDRED FOUR THOUSAND
ONE HUNDRED SEVENTY THREE PESOS AND
SEVENTEEN CENTAVOS [P4,097,804,173.17], more or
less, THEREBY UNJUSTLY ENRICHING HIMSELF OR
THEMSELVES AT THE EXPENSE AND TO THE
DAMAGE OF THE FILIPINO PEOPLE AND THE
REPUBLIC OF THE PHILIPPINES, through ANY OR A
combination OR A series of overt OR criminal acts, OR
SIMILAR SCHEMES OR MEANS, described as follows:
(a) by receiving OR collecting, directly or indirectly, on
SEVERAL INSTANCES, MONEY IN THE AGGREGATE
AMOUNT OF FIVE HUNDRED FORTY-FIVE
MILLION PESOS (P545,000,000.00), MORE OR LESS,
FROM ILLEGAL GAMBLING IN THE FORM OF
GIFT, SHARE, PERCENTAGE, KICKBACK OR ANY
FORM OF PECUNIARY BENEFIT, BY HIMSELF
AND/OR in connivance with co-accused CHARLIE

ATONG ANG, JOSE Jinggoy Estrada, Yolanda T.

Ricaforte, Edward Serapio, AND JOHN DOES AND
JANE DOES, in consideration OF TOLERATION OR
PROTECTION OF ILLEGAL GAMBLING;
(b) by DIVERTING, RECEIVING, misappropriating,
converting OR misusing DIRECTLY OR INDIRECTLY,
for HIS OR THEIR PERSONAL gain and benefit, public
funds in the amount of ONE HUNDRED THIRTY
MILLION PESOS [P130,000,000.00], more or less,
representing a portion of the TWO HUNDRED
MILLION PESOS [P200,000,000.00] tobacco excise tax
share allocated for the Province of Ilocos Sur under R.A.
No. 7171, BY HIMSELF AND/OR in CONNIVANCE
with co-accused Charlie Atong Ang, Alma Alfaro, JOHN
DOE a.k.a. Eleuterio Tan OR Eleuterio Ramos Tan or
Mr. Uy, and Jane Doe a.k.a. Delia Rajas, AND OTHER
JOHN DOES AND JANE DOES;
(c) by directing, ordering and compelling, FOR HIS
PERSONAL GAIN AND BENEFIT, the Government
Service Insurance System (GSIS) TO PURCHASE,
351,878,000 SHARES OF STOCKS, MORE OR LESS,
and the Social Security System (SSS), 329,855,000
SHARES OF STOCK, MORE OR LESS, OF THE
BELLE CORPORATION IN THE AMOUNT OF MORE
OR LESS ONE BILLION ONE HUNDRED TWO
MILLION NINE HUNDRED SIXTY FIVE THOUSAND
SIX HUNDRED SEVEN PESOS AND FIFTY
CENTAVOS [P1,102,965,607.50] AND MORE OR LESS
SEVEN HUNDRED FORTY FOUR MILLION SIX
HUNDRED TWELVE THOUSAND AND FOUR
HUNDRED
FIFTY
PESOS
[P744,612,450.00],
RESPECTIVELY, OR A TOTAL OF MORE OR LESS
ONE BILLION EIGHT HUNDRED FORTY SEVEN
MILLION FIVE HUNDRED SEVENTY EIGHT
THOUSAND FIFTY SEVEN PESOS AND FIFTY
CENTAVOS
[P1,847,578,057.50];
AND
BY
COLLECTING OR RECEIVING, DIRECTLY OR
INDIRECTLY,
BY
HIMSELF
AND/OR
IN
CONNIVANCE WITH JOHN DOES AND JANE DOES,
COMMISSIONS OR PERCENTAGES BY REASON OF
SAID PURCHASES OF SHARES OF STOCK IN THE
AMOUNT OF ONE HUNDRED EIGHTY NINE
MILLION SEVEN HUNDRED THOUSAND PESOS
[P189,700,000.00], MORE OR LESS, FROM THE
BELLE CORPORATION WHICH BECAME PART OF
THE DEPOSIT IN THE EQUITABLE-PCI BANK
UNDER THE ACCOUNT NAME JOSE VELARDE.
(d)
by
unjustly
enriching
himself
FROM
COMMISSIONS, GIFTS, SHARES, PERCENTAGES,
KICKBACKS, OR ANY FORM OF PECUNIARY
BENEFITS, IN CONNIVANCE WITH JOHN DOES
AND JANE DOES, in the amount of MORE OR LESS
THREE BILLION TWO HNDRED THIRTY THREE
MILLION ONE HUNDRED FOUR THOUSAND AND
ONE HUNDRED SEVENTY THREE PESOS AND
SEVENTEEN CENTAVOS [P3,233,104,173.17] AND
DEPOSITING THE SAME UNDER HIS ACCOUNT
NAME JOSE VELARDE AT THE EQUITABLE-PCI
BANK.

CONTRARY TO LAW.
After the prosecution finished presenting its evidence,
former Pres. Estrada filed, with leave of court, a
demurrer to evidence. The demurrer, however, was
denied by the court. Accused Serapio opted not to
present his own evidence, and instead adopted the
evidence presented by Pres. Estrada and Jinggoy
Estrada.
Incidentally, in 2007, the Sandiganbayan approved the
Plea Bargaining Agreement between the prosecution and
accused Atong Ang, the latter pleading guilty to a lesser
offense of Corruption of Public Officials under Article
212 in relation to Article 211 of the Revised Penal Code.
Accused Atong Ang was sentenced to two years and four
months of prision correccional minimum, as minimum,
to six years of prision correccional maximum, as
maximum, and to pay the amount of P25,000,000.00 to
the Government as his civil liability. Accused Atong Ang
is now out of jail under probation.
RULING OF THE COURT
The elements of the crime of plunder, pursuant to RA
7080 and as laid down by the Supreme Court in the
earlier case of Joseph Ejercito Estrada vs.
Sandiganbayan (G.R. No. 148560, 19 November 2001),
are as follows:
(1) That the offender is a public officer who acts by
himself or in connivance with members of his family,
relatives by affinity or consanguinity, business
associates, subordinates or other persons;
(2) That he amassed, accumulated or acquired ill-gotten
wealth through a combination or series of the following
overt or criminal acts described in Section 1 (d) of R.A.
No. 7080 as amended; and
(3) That the aggregate amount or total value of the illgotten wealth amassed, accumulated or acquired is at
least P50,000,000.00.
The terms combination and series were likewise
defined in the above-cited case. Combination refers to at
least two acts falling under different categories of
enumeration provided in Sec. 1, par. (d), e.g., raids on
the public treasury in Sec.1, par. (d), subpar. (1), and
fraudulent conveyance of assets belongings to the
National Government under Sec.1, par. (d), subpar. (3).
On the other hand, to constitute a series, there must be
two or more overt or criminal acts falling under the same
category of enumeration found in Sec. 1, par. (d), say,
misappropriation, malversation and raids on the public
treasury, all of which fall under Sec. 1, par. (d), subpar.
(1).
Section 1 (d) reads:
Ill-gotten wealth means any asset,
property, business enterprise or

material possession of any person

within the purview of Section Two
(2) hereof, acquired by him
directly or in directly through
dummies, nominees, agents,
subordinates and/or business
associates by any combination or
series of the following means or
similar schemes:
1) Through misappropriation,
conversation,
misuse,
or
malversation of public funds or
raids on the public treasury;
2) By receiving, directly or
indirectly, any commission, gift,
share, percentage, kickbacks or
any other form of pecuniary
benefit from any person and/ or
entity in connection with any
government contract or project
or by reason of the office or
position of the public officer
concerned;
3) By the illegal or fraudulent
conveyance or disposition of
asset belonging to the National
Government or any of its
subdivision,
agencies
or
instrumentalities
or
government-owned
or
controlled
corporations
and
their
subsidiaries;
4) By obtaining, receiving or
accepting directly or indirectly
any shares of stock, equity or
any other form of interest or
participation
including
promises of future employment
in any business enterprise or
undertaking;
5) By establishing agricultural,
industrial
or
commercial
monopolies
or
other
combinations
and/or
implementation of decrees and
orders intended to benefit
particular persons or special
interests; or
6) By taking undue advantage
of official position, authority,
relationship, connection or
influence to unjustly enrich
himself or themselves at the
expense and to the damage and
prejudice of the Filipino people

and the Republic

Philippines.

of

the

The prosecution has proven beyond reasonable doubt the

elements of plunder as against former President Estrada,
thus:
(a) The principal accused Joseph Ejercito Estrada, at
the time of the commission of the acts charged in the
Amended Information was the President of the Republic
of the Philippines;
(b) He acted in connivance with then Governor Luis
Chavit Singson, who was granted immunity from suit by
the Office of the Ombudsman, and with the participation
of other persons named by prosecution witnesses in the
course of the trial of this case, in amassing,
accumulating and acquiring ill-gotten wealth as follows:
(i) by a series of acts of receiving bi-monthly collections
from jueteng, a form of illegal gambling, during the
period beginning November 1998 to August 2000 in the
aggregate amount of P545,291,000.00. Out of this
amount, P200,000,000.00 was deposited in the Erap
Muslim Youth Foundation; and
(ii) by a series consisting of two acts of ordering the
GSIS and the SSS to purchase shares of stock of Belle
Corporation and collecting or receiving commission
from the sales of Belle Shares in the amount of
P189,700,000.00 which was deposited in the Jose
Velarde account.
These two acts (i) and (ii) correspond to subparagraphs (a) and (c) of the Amended Information.
However, there is uncertainty as to the participation of
Jinggoy Estrada and Serapio in the allegations under
sub-paragraph (a) of the Amended Information (both are
not included in sub-paragraph [c] of the Amended
Information).
With respect to Jinggoy Estrada, there was no evidence
that the money he turned over to Gov. Singson or the
latter as representatives was part of the jueteng
protection money collected from Bulacan or that he
received funds from a certain Viceo. The prosecution did
not also rebut the bank certification presented by the
defense that Jinggoy Estrada did not have an account
with the United Overseas Bank, disproving the
testimony of Emma Lim that the deposit slip in the
amount said to be part of jueteng money was turned over
to her by Jinggoy Estrada from his account at the United
Overseas Bank. The gaps in the prosecution as evidence
as to Jinggoy Estrada create uncertainty in the mind of
the Court as to the participation of Jinggoy Estrada in the
collection and receipt of jueteng money.
With respect to Serapio, neither Gov. Chavit Singsons
testimony nor the ledger entries proved that Serapio was
involved in any way in the collection or disbursement of
jueteng protection money. It is difficult to presume any
criminal intent on the part of Serapio to conceal or

launder jueteng protection money in order to contribute

to the amassing and accumulation of ill-gotten wealth by
Former Pres. Estrada in connection with the transfer of
the P200, 000,000.00 to the Erap Muslim Youth
Foundation.
On the other hand, the prosecution failed to establish
beyond reasonable doubt the allegations under subparagraph (b) and (d) of the amended Information:
1. Acts under sub-paragraph (b) of the Amended
Information. With respect to the act of divesting,
receiving or misappropriating a portion of the tobacco
excise tax share allocated for the Province of Ilocos Sur,
the paper trail in relation to the P130,000,000.00
diverted tobacco excise taxes began with Gov. Singson
and ended with Atong Ang. This Court does not find the
evidence sufficient to establish beyond reasonable doubt
that FPres. Estrada or any member of his family had
instigated and/or benefited from the diversion of said
funds. The prosecution failed to prove, beyond
reasonable doubt, who among the accused benefited
from the misappropriation of the excise tax share of
Ilocos Sur and in what amounts.
2. Acts under sub-paragraph (d) of the Amended
Information. While the prosecution presented
overwhelming evidence that there were numerous
deposits of astoundingly large sums of money into the
Jose Velarde account, it failed to prove the predicate
act/s as defined under Section 1(d) of R.A. No. 7080
through which the said deposits could have been
acquired or amassed, except for the amount of
P189,700,000.00, representing illegal commissions from
the sales of Belle shares and the money collected from
illegal gambling. It is not per se the accumulation of
wealth which is proscribed by the Anti-Plunder Law. The
acquisition of wealth of not less than P50,000,000.00
must be linked to the commission of overt or criminal
acts falling within the ambit of the said law. All that the
prosecution has succeeded in showing is that the Jose
Velarde account is the repository or receptacle of vast
wealth belonging to FPres. Estrada.
However, the two different series of predicate acts
outlined above (particularly, first, the regular and
methodical acquisition of ill-gotten wealth through
collections from illegal gambling, and, second, the
receipt of unlawful commissions from the sales of Belle
shares twice), whether taken separately or independently
of the other or in combination with each other,
unquestionably constitute the crime of plunder as
defined by Section 2, in relation to Section 1(d) of RA
7080 as amended.
A pattern was established by the carefully planned
system of jueteng money collection on a regular bimonthly basis from the dfferent provinces nationwide to
enrich FPres. Estrada with the connivance and/or
participation of Gov. Singson, Yolanda Ricaforte, Emma
Lim, Carmencita Itchon, SPO2 Artates, Jamis Singson
and other jueteng collectors referred to in the Amended
Information as John Does and Jane Does. As proven, the

collections in several instances from illegal gambling

money went way beyond the minimum of
P50,000,000.00 set by the Anti-Plunder Law. These
repeated collections of jueteng money from November
1998 to August 2000 would fall within the purview of a
series of illegal acts constituting plunder. The said
series of acts, on its own, would have been sufficient to
convict the principal accused, FPres. Estrada. However,
this Court also finds that FPres. Estrada is criminally
liable for plunder for receiving commissions from the
purchase of Belle Shares by the GSIS and by the SSS in
grave abuse of his power on two separate occasions as
charged in sub-paragraph (b) of the Amended
Information. Clearly, the receipt of these commissions
on two occasions likewise meets the definition of a
series of two similar unlawful acts employing the same
scheme to accumulate ill-gotten wealth.
It is unnecessary to indulge in an exposition of whether
the two series of acts falling under sub-paragraphs (a)
and (c) of the Amended Information, proven in the
course of the trial could have amounted to two (2) counts
of plunder. It would be a purely academic exercise, as
the accused cannot be convicted of two offenses or two
counts of plunder on the basis of a single Information,
clearly charging him of only one count of plunder,
because that would violate his constitutional rights to
due process, given the severity of the crime charged in
this case.
The predicate acts alleged in sub-paragraphs (a) and (c)
of the Amended Information, which formed two separate
series of acts of a different nature, were linked by the
fact that they were plainly geared towards a common
goal which was the accumulation of ill-gotten wealth for
FPres. Estrada and that they shared a pattern or a
common method of commission which was the abuse or
misuse of the high authority or power of the Presidency.
In sum, the Court finds that prosecution has proven
beyond reasonable doubt the commission by the
principal accused former President Joseph Ejercito
Estrada of the crime of plunder but not so in the case of
former Mayor Jose Jinggoy Estrada and Atty. Edward
Serapio.
THE DISPOSITIVE PORTION
Former President Joseph Ejercito Estrada is GUILTY
beyond reasonable doubt of the crime of PLUNDER,
defined in and penalized by Republic Act No. 7080, as
amended. On the other hand, for failure of the
prosecution to prove and establish their guilt beyond
reasonable doubt, the Court finds the accused Jose
Jinggoy Estrada and Atty. Edward S. Serapio NOT
GUILTY of the crime of plunder, and accordingly, the
Court hereby orders their ACQUITTAL.
The penalty imposable for the crime of plunder under
Republic Act No. 7080, as amended by Republic Act No.
7659, is Reclusion Perpetua to Death. There being no
aggravating or mitigating circumstances, however, the
lesser penalty shall be applied in accordance with Article

63 of the Revised Penal Code. Accordingly, accused

Former President Joseph Ejercito Estrada is hereby
sentenced to suffer the penalty of Reclusion
Perpetua and
the
accessory penalties
of civil
interdiction during the period of sentence and perpetual
absolute disqualification.
Moreover, in accordance with Section 2 of Republic Act
No. 7080, as amended by Republic Act No. 7659, the
Court hereby declares the forfeiture in favor of the
government of the following: (1) The total amount of
P545,291,000.00, with interest and income earned,
inclusive of the amount of P200,000,000.00, deposited in
the name and account of the Erap Muslim Youth
Foundation; (2) The amount of P189,000,000.00,
inclusive of interests and income earned, deposited in the
Jose Velarde account; and (3) The real property
consisting of a house and lot dubbed as Boracay
Mansion located at #100 11th Street, New Manila,
Quezon City.
What is the applicable law on plunder?
Plunder is covered by Republic Act No. 7080 (An Act
Defining and Penalizing the Crime of Plunder), as
amended.
Is the law unconstitutional?
No. The Supreme Court already ruled in Estrada vs.
Sandiganbayan (2001) that RA 7080 is not contrary to
the Constitution.
Whats the definition of a public officer?
A public officer means any person holding any public
office in the Government of the Republic of the
Philippines by virtue of an appointment, election or
contract.
What is included in the term government in the
definition above?
Government includes the National Government and any
of its subdivision, agencies or instrumentalities,
including
government-owned
or
controlled
corporations and their subsidiaries.
What is ill-gotten wealth?
Ill-gotten wealth means any asset, property, business
enterprise or material possession of any person within
the purview of Section 2 (defining the crime of plunder)
of the law, acquired by him directly or indirectly through
dummies, nominees, agents, subordinates and/or
business associates by any combination or series of the
following means or similar schemes:
1. Through misappropriation, conversion,
misuse, or malversation of public funds or raids on the
public treasury;
2. By receiving, directly or indirectly, any
commission, gift, share, percentage, kickbacks or any
other form of pecuniary benefit from any person and/or
entity in connection with any government contract or
project or by reason of the office or position of the
public officer concerned;
3. By the illegal or fraudulent conveyance or
disposition of assets belonging to the National
Government or any of its subdivisions, agencies or
instrumentalities or government-owned or controlled
corporations and their subsidiaries;

4. By obtaining, receiving or accepting directly

or indirectly any shares of stock, equity or any other
form of interest or participation including promise of
future employment in any business enterprise or
undertaking;
5. By establishing agricultural industrial or
commercial monopolies or other combinations and/or
implementation of decrees and orders intended to benefit
particular persons or special interests; or
6. By taking undue advantage of official
position, authority, relationship, connection or influence
to unjustly enrich himself or themselves at the expense
and to the damage and prejudice of the Filipino people
and the Republic of the Philippines.
What are the elements of the crime of plunder?
As discussed in Estrada vs. Sandiganbayan (2001), the
elements of the crime of plunder are:
1. That the offender is a public officer who acts
by himself or in connivance with members of his family,
relatives by affinity or consanguinity, business
associates, subordinates or other persons;
2. That he amassed, accumulated or acquired
ill-gotten wealth through a combination or series of the
following overt or criminal acts:
a)
through
misappropriation,
conversion, misuse, or malversation of public
funds or raids on the public treasure;
b) by receiving, directly or directly,
any commission, gift, share, percentage,
kickback or any other form of pecuniary
benefits from any person and/or entity in
connection with any government contract or
project or by reason of the office or position of
the public officer;
c) by the illegal or fraudulent
conveyance or disposition of assets belonging
to the National Government or any of its
subdivision, agencies or instrumentalities of
Government owned or controlled corporations
or their subsidiaries;
d) by obtaining, receiving or accepting
directly or indirectly any shares of stock, equity
or any other form of interest or participation
including the promise of future employment in
any business enterprise or undertaking;
e) by establishing agricultural,
industrial or commercial monopolies or other
combinations and/or implementation of decrees
and orders intended to benefit particular
persons or special interest; or
f) by taking advantage of official
position, authority, relationship, connection or
influence to unjustly enrich himself or
themselves at the expense and to the damage
and prejudice of the Filipino people and the
Republic of the Philippines; and
3. That the aggregate amount or total value of
the ill-gotten wealth amassed, accumulated or
acquired is at least P50,000,000.00.
[Note: The threshold amount is originally P75 Million
under RA 7080. This was amended by RA 7659, which is
an act imposing the death penalty on certain heinous

crimes including plunder, decreasing the threshold

amount to P50 Million. We all know, however, that the
death penalty law (RA 7659) was repealed or amended
accordingly by RA 9346 (2006), which prohibits the
imposition of the death penalty. The interesting point is
this does the repeal (or amendment) or RA 7659
mean that the threshold amount is now back to
P75Million?]
What is the court that has jurisdiction over the crime of
plunder?
Until otherwise provided by law, all prosecutions under
the law is at the Sandiganbayan. The Supreme Court
clarified that the Sandiganbayan has no jurisdiction over
the crime of plunder unless committed by public officials
and employees occupying the positions with Salary
Grade 27 or higher, under the Compensation and
Position Classification Act of 1989 (Republic Act No.
6758) in relation to their office. This is pursuant to
Republic Act No. 8429 (1997), which is the special law
that provided for the jurisdiction of the Sandiganbayan
otherwise than that prescribed in Republic Act No.
7080.
What is the specific rule of evidence provided under this
law?
For purposes of establishing the crime of plunder, it shall
not be necessary to prove each and every criminal act
done by the accused in furtherance of the scheme or
conspiracy to amass, accumulate or acquire ill-gotten
wealth, it being sufficient to establish beyond reasonable
doubt a pattern of over or criminal acts indicative of the
overall unlawful scheme or conspiracy.
What is the effect of a charge of plunder on a public
office still in office?
Any public officer against whom any criminal
prosecution under a valid information under this law in
whatever stage of execution and mode of participation, is
pending in court, shall be suspened from office.
What is the applicable penalty upon conviction?
The applicable penalty for the crime of Plunder, under
RA 7080 (as amended by RA 7659), is reclusion
perpetua to death. The death penalty, however, was
already abolished, which means that the applicable
penalty is reclusion perpetua, without prejudice to other
accessory penalties that may be imposed by the court.
Upon conviction, what is the other penalty in addition to
imprisonment?
In case of conviction by final judgment, the accused
shall lose all retirement or gratuity benefits under any
law. However, if the accused is acquitted, he shall be
entitled to reinstatement and to the salaries and other
benefits which he failed to receive during suspension,
unless in the meantime, administrative proceedings have
been filed against him.
Is there a prescriptive period in prosecuting someone
with plunder?
Yes, the crime punishable under RA 7080 prescribes in
twenty (20) years. However, the right of the State to
recover properties unlawfully acquired by public officers
from them or from their nominees or transferees shall
not be barred by prescription, laches or estoppel .
References
http://jlp-law.com/blog/the-law-on-plunder/
http://www.economicsdiscussion.net/articles/what-arethe-main-stages-of-economic-growth/2044
http://en.wikipilipinas.org/index.php/Plunder

http://www.doj.gov.ph/major-cases.html
http://jlp-law.com/blog/the-plunder-law-ra-7080-fulltext/
http://jlp-law.com/blog/people-philippines-vs-josephestrada-sandiganbayan-criminal-case-26558-plunder/

http://jlp-law.com/blog/
http://www.lawphil.net/courts/sandigan/sb_26558_2007.
html