Republic of the Philippines SANDIGANBAYAN Quezon City ECIAL PEOPLE OF THE PHILIPPINES, PLAINTIFF, CRIM. CASE NO. 26905 ~ VERSUS - FOR: PERJURY JOSEPH EJERCITO ESTRADA, £7 AL., ACCUSED. Yom eect PLAINTIFF'S MEMORANDUM OFFICE OF THE OMBUDSMAN OFFICE OF THE SPECIAL PROSECUTOR SPECIAL PROSECUTION PANEL SANDIGANBAYAN CENTENNIAL BUILDING COMMONWEALTH AVENUE QUEZON CITYRepublic of the Philizpines SANDIGANBAYAN Quezon City SPECIAL DIVISION PEOPLE OF THE PHILIPPINES, Praintiff, - versus ~ Crim. Case No, 26905 For: Perjury JOSEPH EJERCITO ESTRADA, Accused. x x MEMORANDUM FOR THE PEOPLE THE PEOPLE OF THE PHILIPPINES, by the eed vv Special Prosecution Panel and unto this Honorable Court, hereél respectfully avers that: PREFATORY STATEMENT “Man exists as an end himself, not merely as a means, who is thinking of making a lying promise to others wilt sée at an that he would be using another man merely as a mean without u fatter containing at the same time the end in himself,” - Immantk Kant, First Principles of the Meta-Physics of Morals. The ‘instant case is very simple.Memorandum for the People P vs, Joseph Blercite Estrada Crim, Case No. 26905 On April 29, 1999, accused former President of the Repubtle af the Phillppines Joseph E€jercito Estrada filed his Sworn Statement | Assets, Liabilities and Net Worth (SALN) under oath reporting hip and his wife’s supposed assets, liabilities and net worth as of December 31, 1998 vith the Office of the Ombudsman, as requiret by Republic Act Numbered 6713. Such Sworn Statement contained his purported personal properties which Included his cash on han and in bank in the amount of Five Million Four Hundred Thirty nal Thousand Three Hundred Sixty Three and 40/100 Peso! (P5,435,363.40). The sworn statement also contained sonal business interests and financial connections of his wife, namely] JELP Real: Estate Development Corporation, J.E. Inc. and Fe Luisa Development Corporation. Such sworn statement, however, did not include monies of accused Estrada deposited in various banks as of December 31 1998, namely: Forty Four Million Two Hundred Sixty-Elght Thousand Four Hundred Forty-Two and 68/100 Pesos | (P44,268,442.68) in Keppel Bank, San Juan Branch; Ten Million Eight Hundred Seventeen Thousand Fifty ‘Two and 32/109 Pesos (P10,817,052.525 in Investment Saving Account No. 09405“ 10-00, Six Hundred Fifty Five Thousand Six Hundred Thirty Bight Pesos (P655,638.00) In Treasury gills, Seven Hundred Twelve 3