REPUBLIC OF THE PHILIPPINES

SANDIGANBAYAN

Quezon City

SPECIAL DIVISION

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - CRIM. CASE NO. 26558

JOSEPH EJERCITO ESTRADA,

ET AL.,

Accused.

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MOTION FOR RECONSIDERATION

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ACCUSED Pres. Joseph Ejercito Estrada, through the undersigned counsel, respectfully moves for the reconsideration of the Decision of the Honorable Court dated September 1, 2007 on the following grounds:

GROUNDS FOR RECONSIDERATION

I. MISTRIAL: THE ACCUSED PRES. ESTRADA WAS DEPRIVED OF HIS CONSTITUTIONAL RIGHT TO DUE PROCESS AND TO BE INFORMED OF THE NATURE AND CAUSE OF THE ACCUSATION AGAINST HIM.

II. THE ACCUSED WAS LIKEWISE DEPRIVED OF HIS CONSTITUTIONAL RIGHT TO BE INFORMED WHEN HE WAS CONVICTED OF AN OFFENSE NOT INCLUDED IN THE INFORMATION.

III. NOT ACCUSED, BUT OTHERS, DID “AMASS, ACCUMULATE, OR ACQUIRE” ILL-GOTTEN WEALTH UNDER SUBPARAGRAPH (A) AND (C) OF THE AMENDED INFORMATION.

IV. THE ACCUSED PRES. ESTRADA WAS DEPRIVED OF HIS CONSTITUTIONAL RIGHT TO CONFRONT WITNESSES AGAINST HIM WHEN HEARSAY EVIDENCE AGAINST HIM WAS ADMITTED.

V. THE ACCUSED PRES. ESTRADA WAS DENIED HIS CONTITUTIONAL RIGHT TO PRESUMPTION OF INNOCENCE AS THE COURT CONVICTED HIM ON THE BASIS OF SURMISES, INFERENCES AND SPECULATIVE EVIDENCE.