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:

Parties and Employment Background

• Rolando L. Balderama and Rolando D. Nagal were employees of the Land Transportation Commission (LTO), assigned to the Field Enforcement Division, Law Enforcement Services.
• Juan S. Armamento, respondent in both cases, is a taxi operator owning a fleet of ten taxi units.

Formation of the Investigative Team and Incident Initiation

• In response to complaints that taxi drivers at Ninoy Aquino International Airport discriminated against passengers and rendered service on a contracta basis, the LTO constituted a team popularly known as the “Flying Squad.”
• Petitioners Balderama and Nagal, along with other team members Cipriano L. Lubrica and Cresencio de Jesus, were tasked to verify these complaints.
• On July 14, 1992, the team flagged down and impounded one of Armamento’s taxis on the ground that its meter was defective, although later tests confirmed that the meter’s waiting time mechanism was functioning properly.

The Bribery Allegation and Subsequent Complaint

• Feeling aggrieved by what he perceived as a malicious and unwarranted impounding of his vehicle, Armamento filed a complaint on December 2, 1992, with the Office of the Ombudsman for bribery and violation of Section 3(e) of Republic Act No. 3019, as amended.
• It was alleged that prior to the impounding, the officers had been collecting “protection money”—an arrangement where on February 15, 1992, they proposed that Armamento should avoid having his drivers apprehended and his vehicles impounded if he paid a periodic bribe.
• Although an initial demand of P400.00 was made, the amount was reduced to P300.00, which Armamento duly paid on several occasions until his payments ceased when his business declined.

Criminal Proceedings and Charges

• The Office of the Ombudsman subsequently filed nine Informations before the Sandiganbayan for violations of Article 210 of the Revised Penal Code, with each Information nearly identical except for the date of the alleged offense.
• For illustration, Criminal Case No. 20669 detailed accusations that the public officers, in exchange for refraining from inspecting the taxi units, received P300.00 directly from Armamento, thereby causing him damage.
• A separate Information, Criminal Case No. 20678, charged the accused with a violation of Section 3(e) of R.A. No. 3019 for the wrongful impounding of the taxi that resulted in economic loss for Armamento.

Trial Proceedings and Court Findings

• Upon arraignment on June 30, 1994, the accused pleaded not guilty.
• The cases were consolidated and tried jointly, with the accused initially suspended from service.
• In the decision dated November 17, 2000, the Sandiganbayan found petitioners and Lubrica guilty of direct bribery in seven of the nine Informations and imposed indeterminate penalties of prision correccional along with fines and special temporary disqualification from public office.
• Additionally, in Criminal Case No. 20678, petitioners and Lubrica were convicted for violating Section 3(e) of R.A. No. 3019, receiving prison terms as well as an order to indemnify Armamento for the economic loss he suffered.

Motions, Recantations, and Post-Conviction Proceedings

• After conviction, petitioners and co-accused filed separate motions for reconsideration and new trial.
• These motions were primarily based on arguments that they were not yet officially grouped as a team on February 15, 1992, and on an affidavit of recantation executed by Armamento, which attempted to absolve them by pointing to other individuals as the culprits.
• The Sandiganbayan denied the motions for reconsideration and new trial on March 20, 2001, upholding their findings of conspiracy and deeming the recantation as unreliable.

Petition for Review on Certiorari

• Petitioners Balderama and Nagal separately filed petitions for review on certiorari with the Supreme Court, contesting the Sandiganbayan’s findings on multiple grounds:

- That their guilt in the offenses charged was not proved beyond reasonable doubt. - That the finding of a conspiracy among them was erroneous. - That the court improperly disregarded the recantation of Armamento.

Issue:

• Whether the evidence presented at trial established beyond reasonable doubt that the accused, as public officers, solicited, demanded, and received bribes from Juan Armamento.
• Whether the accused participated in a conspiracy to commit direct bribery by collectively agreeing to refrain from exercising their official duties in exchange for monetary gains.
• Whether the recantation affidavit submitted by Armamento, the private complainant, should have been given substantial weight to exonerate the accused from their alleged criminal acts.
• Whether the factual findings of the Sandiganbayan, being binding and conclusive, were improperly disturbed by the allegations of inconsistency in the evidence and the subsequent motions for new trial and reconsideration.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)