Case Digest (G.R. No. 147578-85) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Balderama v. People, petitioners Rolando L. Balderama and Rolando D. Nagal were officers of the Land Transportation Office (LTO) assigned to its Field Enforcement Division. In February and July 1992, they formed part of a special “Flying Squad” tasked to investigate complaints of taxi discrimination at Ninoy Aquino International Airport. On July 14, 1992, they impounded one taxi unit of respondent Juan S. Armamento on the ground of a defective meter, but an LTO inspection subsequently proved the meter fully operational and the vehicle was released. Aggrieved, Armamento filed with the Office of the Ombudsman on December 2, 1992, a complaint for direct bribery under Article 210 of the Revised Penal Code and for violation of Section 3(e) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), alleging that petitioners and two colleagues had been collecting ₱300 every 15th and 30th day of the month from February to June 1992 as a “protection fee” in exchange for refraini Case Digest (G.R. No. 147578-85) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Consolidation and Parties
- Rolando L. Balderama and Rolando D. Nagal, petitioners, employed by the Land Transportation Office (LTO) Field Enforcement Division (“Flying Squad”).
- Respondent Juan S. Armamento, taxi operator, and the People of the Philippines.
- Underlying Incident and Complaint
- July 14, 1992: Flying Squad impounded Armamento’s taxi for a purportedly defective meter, later found to be functioning normally.
- December 2, 1992: Armamento filed a complaint with the Ombudsman alleging that from February 15 to June 15, 1992, petitioners and co‐accused demanded and received P300 every 15th and 30th day as “protection money.”
- Prosecution and Trial Proceedings
- The Ombudsman filed nine (9) Informations for direct bribery under Article 210, Revised Penal Code (RPC), and one (1) Information for violation of Section 3(e), Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act).
- Arraigned June 30, 1994; petitioners pleaded not guilty; suspended pendente lite for 90 days.
- March 5, 1999: Co-accused de Jesus died; cases against him dismissed.
- November 17, 2000: Sandiganbayan convicted Balderama and Nagal of direct bribery in seven counts and of Sec. 3(e), RA 3019, in one count; acquitted in two counts; imposed prison terms, fines, disqualifications, restitution (P300) and indemnity (P1,500).
- March 20, 2001: Sandiganbayan denied motions for reconsideration (conspiracy finding) and new trial (recantation affidavit).
Issues:
- Whether the prosecution proved beyond reasonable doubt the elements of direct bribery under Art. 210, RPC.
- Whether the accused acted in conspiracy in soliciting protection money.
- Whether the complainant’s post-conviction recantation affidavit warranted a new trial.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)