Facts:

The case involves two consolidated petitions for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure, filed by Rolando L. Balderama and Rolando D. Nagal against the People of the Philippines and Juan S. Armamento. The events leading to the case began on July 14, 1992, when a team from the Land Transportation Commission (LTO), known as the "Flying Squad," which included the petitioners, flagged down a taxi owned by Armamento for inspection at the Ninoy Aquino International Airport. The team impounded the taxi, claiming that its meter was defective. However, subsequent inspection by the LTO Inspection Division revealed that the meter was functioning normally, leading to the release of the vehicle.

Feeling aggrieved by the impounding, Armamento filed a complaint with the Office of the Ombudsman on December 2, 1992, alleging bribery and violations of the Anti-Graft and Corrupt Practices Act against the petitioners and their colleagues. He claimed t...

Facts:

Background and Parties Involved:
Rolando L. Balderama and Rolando D. Nagal, petitioners, were employed with the Land Transportation Commission (LTO) and assigned to the Field Enforcement Division, Law Enforcement Services. Juan S. Armamento, the respondent, operated a taxi business with a fleet of ten taxi units.

Complaints and Investigation:
Acting on complaints that taxi drivers at Ninoy Aquino International Airport discriminated against passengers and operated on a "contract" basis, the LTO formed a team to investigate. Petitioners were part of this team, known as the "Flying Squad," along with Cipriano L. Lubrica and Cresencio de Jesus.

Incident of July 14, 1992:
The team flagged down an "SJ Taxi" owned by respondent for inspection, impounded it on grounds of a defective meter. However, subsequent testing by the LTO Inspection Division revealed the meter was functioning normally, and the vehicle was released to respondent.

Complaint Filed by Respondent:
On December 2, 1992, respondent filed a complaint with the Office of the Ombudsman, alleging that prior to the impounding, petitioners and their co-members had been collecting "protection money" from him. He claimed they demanded P400.00 every 15th and 30th day of the month, later reduced to P300.00, in exchange for not apprehending his drivers or impounding his vehicles.

Filing of Informations:
The Office of the Ombudsman filed nine Informations with the Sandiganbayan, charging petitioners and their co-members with direct bribery under Article 210 of the Revised Penal Code and violation of Section 3(e) of R.A. No. 3019 (Anti-Graft and Corrupt Practices Act).

Trial and Conviction:
After arraignment and trial, the Sandiganbayan convicted petitioners and Lubrica of direct bribery in seven Informations and violation of Section 3(e) of R.A. No. 3019. They were sentenced to imprisonment, fines, and disqualification from public office.

Motions for Reconsideration and New Trial:
Petitioners filed motions for reconsideration, arguing they were not part of a team on February 15, 1992. They also filed motions for new trial based on respondent’s affidavit recanting his previous testimony. These motions were denied.

Issue:

1. Whether the guilt of petitioners for direct bribery and violation of Section 3(e) of R.A. No. 3019 was proved beyond reasonable doubt.
2. Whether the Sandiganbayan erred in finding petitioners acted in conspiracy.
3. Whether the Sandiganbayan erred in disregarding respondent’s affidavit of recantation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)