Easy. Impeach Arroyo in 2009 for Election fraud and corruption. Whether Noli decides to stay on and assume the presidency or if he resigns, it's LOSE-LOSE for him. Here's why.
And for people who are worried about Noli as acting president, if you impeach arroyo in 2009, you get to elect a new president in 2010. Isang taon lang ang stay ni Kabayad sa pagka-presidente.
So two birds in one stone. Not only do you effectively prevent a possible Noli presidency beyond 2010, you get to put arroyo and garci in jail too.