Facts:

The case involves Liwanag Aguirre, the petitioner, who was found guilty of direct bribery by the Sandiganbayan (First Division) in a decision dated October 30, 1987. The events leading to the case occurred on November 24, 1978, in Davao City, Philippines. Aguirre, at the time, served as an Acting Deputy Sheriff of the National Labor Relations Commission (NLRC). The Information filed against him alleged that he unlawfully demanded and received Fifty Pesos (P50.00) from Hermogenes Hanginon, an employee of Guardsman Security Agency. This act was purportedly in exchange for Aguirre's decision to refrain from executing a Writ of Execution related to a final judgment against the security agency in NLRC Case No. 905-MC-XI-78. Following his not guilty plea, the case proceeded to trial, where the Sandiganbayan convicted Aguirre based on the evidence presented, particularly the testimony of Hanginon. The court acknowledged the mitigating ...

Facts:

1. Parties Involved:

   • Petitioner: Liwanag Aguirre, an Acting Deputy Sheriff of the National Labor Relations Commission (NLRC).
   • Respondents: People of the Philippines and the Sandiganbayan (First Division).

2. Charges:

   • Liwanag Aguirre was charged with direct bribery under Article 210 of the Revised Penal Code.
   • The Information alleged that on November 24, 1978, in Davao City, Aguirre demanded and received P50.00 from Hermogenes Hanginon, an employee of Guardsman Security Agency, in exchange for refraining from immediately implementing a Writ of Execution against the agency in NLRC Case No. 905-MC-XI-78.

3. Trial and Conviction:

   • Aguirre pleaded not guilty, and the case proceeded to trial.
   • The Sandiganbayan convicted Aguirre, appreciating the mitigating circumstance of voluntary surrender and imposing the following penalties:
     • Two (2) Months and One (1) Day of Arresto Mayor.
     • Special temporary disqualification for Six (6) Years and One (1) Day.
     • A fine of P50.00 with subsidiary imprisonment in case of insolvency.
     • Indemnification of Hermogenes Hanginon in the amount of P50.00.

4. Petitioner’s Defense:

   • Aguirre argued that the evidence presented was insufficient to prove his guilt beyond reasonable doubt.
   • He contended that the Sandiganbayan erred in relying on the uncorroborated testimony of Hermogenes Hanginon, the lone prosecution witness.

5. Prosecution’s Evidence:

   • The prosecution’s case rested solely on the testimony of Hermogenes Hanginon, who claimed that Aguirre demanded a bribe to delay the implementation of the Writ of Execution.

6. Defense’s Evidence:

   • Aguirre asserted that the garnishment of the agency’s bank account had already been initiated before the alleged bribery occurred, casting doubt on the necessity of the bribe.

Issue:

1. Main Issue:

   • Whether the Sandiganbayan erred in convicting Liwanag Aguirre based on the uncorroborated testimony of a single witness, Hermogenes Hanginon.

2. Sub-Issues:

   • Whether the testimony of a lone witness is sufficient to establish guilt beyond reasonable doubt.
   • Whether the circumstances surrounding the alleged bribery were credible and consistent with human experience.
   • Whether the constitutional presumption of innocence was properly observed.

Ruling:

The Supreme Court reversed the decision of the Sandiganbayan and acquitted Liwanag Aguirre of the crime of direct bribery.

Ratio:

1. Credibility of a Lone Witness:

   • While the testimony of a single witness can be sufficient to support a conviction if it convinces the court beyond reasonable doubt, the testimony must be credible and consistent.
   • In this case, the testimony of Hermogenes Hanginon was found to be doubtful and unnatural.

2. Unnatural Circumstances:

   • It was deemed unlikely that Aguirre would demand a bribe from Hanginon, a mere employee without authority to handle legal matters or funds.
   • The absence of an entrapment operation, despite the opportunity to do so, further weakened the prosecution’s case.

3. Constitutional Presumption of Innocence:

   • The constitutional presumption of innocence requires that guilt be proven beyond reasonable doubt.
   • The Court found that the evidence presented by the prosecution failed to meet this standard.

4. Doubt in Favor of the Accused:

   • In criminal cases, any reasonable doubt must be resolved in favor of the accused.
   • The Court emphasized that the scales of justice must tip in favor of the accused when evidence is insufficient or doubtful.

5. Reversal of Conviction:

   • Due to the lack of sufficient evidence to prove Aguirre’s guilt beyond reasonable doubt, the Court reversed the Sandiganbayan’s decision and acquitted him.

Conclusion:

The Supreme Court acquitted Liwanag Aguirre, emphasizing the constitutional presumption of innocence and the insufficiency of the prosecution’s evidence. The testimony of the lone witness was deemed unreliable, and the circumstances surrounding the alleged bribery were found to be inconsistent with human experience.