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:

Case Background

• The case involves petitioner Liwanag Aguirre challenging his conviction by the Sandiganbayan (First Division) for the crime of direct bribery under Article 210 of the Revised Penal Code.
• The controversy centers on the alleged demand and acceptance of a bribe in connection with the execution of a writ of execution issued against Guardsman Security Agency following an NLRC judgment.

Allegations and Circumstances of the Offense

• It is alleged that on or about November 24, 1978, in the City of Davao, Aguirre—then serving as an Acting Deputy Sheriff of the NLRC—wilfully, unlawfully, and feloniously demanded and obtained from Hermogenes Hanginon, an employee of Guardsman Security Agency, a sum of Fifty Pesos.
• The bribe was purportedly received as consideration for Aguirre’s failure to immediately implement a writ of execution, which involved seizing the personal property of the judgment debtor, thereby satisfying the NLRC’s final judgment against the security agency.

Trial and Conviction

• Petitioner Aguirre pleaded not guilty at trial, but the case proceeded to trial where the prosecution relied significantly on the testimony of the sole witness, Hermogenes Hanginon.
• The evidence presented, primarily the uncorroborated testimony of Hanginon, formed the basis of the conviction.
• The Sandiganbayan took note of mitigating circumstances, particularly Aguirre’s voluntary surrender, and noted the absence of aggravating circumstances, which influenced the sentencing.
• The sentence imposed included:
• Two (2) Months and One (1) Day of Arresto Mayor,
• Special temporary disqualification for Six (6) Years and One (1) Day,
• A fine of Fifty Pesos with subsidiary imprisonment in case of insolvency in accordance with Article 39 of the Revised Penal Code as amended by Republic Act No. 5465,
• Indemnification of Hermogenes Hanginon in the same amount of Fifty Pesos,
• Payment of the legal costs.

Defense Arguments and Evidentiary Concerns

• Aguirre argued that the conviction was based solely on the testimony of a single prosecution witness and that such uncorroborated evidence failed to prove his guilt beyond reasonable doubt.
• The defense also raised factual disputes regarding the commission of the offense, including challenges to the plausibility of a bribe being demanded by an employee with no legal authority and the unusual circumstances surrounding the alleged event.
• Additionally, the defense highlighted an alternative explanation involving a prior execution of garnishment on a bank account for satisfaction of the NLRC judgment, suggesting that the bribery incident might have been unnecessary.

Issue:

Sufficiency of the Evidence

• Whether the sole uncorroborated testimony of Hermogenes Hanginon is sufficient to establish beyond reasonable doubt that Aguirre committed the crime of direct bribery.

Credibility and Reliability of the Prosecution Witness

• Whether the testimony of Hanginon, as presented, carries the ring of truth without any supporting evidence or corroboration.
• Whether the demeanor, spontaneity, and details provided by Hanginon sufficiently counterbalance the constitutional presumption of innocence.

Application of the Constitutional Presumption of Innocence

• Whether the trial court, by relying on the single witness testimony, failed to overcome the constitutional burden of proving guilt beyond reasonable doubt.

Procedural and Evidentiary Considerations

• Whether the absence of an entrapment scenario, inconsistencies in the alleged sequence of events (such as the handling of the remaining bribe money), and the credibility concerns regarding the witness’s account, should have led to an acquittal.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)