G.R. No. 14595 - Sarasola vs. Trinidad

On October 30, 1997, Magdalena M. Hugglan[d] filed a complaint for bribery against Judge Jose C. Lantin before the District Office of the National Bureau of Investigation (NBI) in Olongapo City.
The complaint stemmed from an alleged incident in which Judge Lantin, then Presiding Judge of the Municipal Trial Court (MTC) of San Felipe, Zambales, purportedly demanded money in exchange for cancelling a hold departure order previously issued against the complainant.
Prior to the bribery complaint, the complainant had been involved in a murder case (Crim. Case No. 3886) where a hold departure order had been imposed on her as a respondent in the preliminary investigation initiated by SPO4 Lorenzo A. Feria.
After the preliminary investigation, Judge Lantin had recommended the filing of an information for murder without granting bail, and later transmitted the case records to the Provincial Prosecutor of Zambales.

In the wake of the complaint, an entrapment operation was planned and executed on November 12, 1997, where the complainant was instructed by NBI agents to deliver money to Lantin.
The operation involved a coordinated effort by NBI agents, including Special Agent Jesusa D. Jamasali, Agent David P. Golla, and Supervising Agent Joel A. Curammeng.
During the operation:

The complainant, accompanied by an NBI agent posing as her cousin, entered Judge Lantin’s office.
She delivered an envelope containing marked money amounting to P5,000.00, deliberately placed by her in one of the left drawers of the respondent’s table.
After a brief conversation, Judge Lantin used a piece of newspaper as a cover while counting the money, after which the envelope and money were left behind.

The entrapment was later followed by the immediate arrest of Judge Lantin by the NBI agents, who read him his rights.

Her own detailed Sinumpaang Salaysay recounting the events, whereby she claimed that after paying an initial amount of P12,000.00 on April 30, 1997, the respondent demanded an additional P13,000.00 upon his subpoena issued on October 30, 1997.
The correspondence and documents indicating that the Motion to Quash the Hold Departure Order and the subsequent Order of Cancellation were personally prepared and typewritten by Judge Lantin.
Exhibits consisting of affidavits, joint-affidavits by arresting NBI officers, and various documentary evidences (money records, envelopes, newspapers, etc.).

His counter-affidavit, where he denied receiving any money and claimed that the marked money was planted after his office was searched.
Testimonies alleging that the subpoena was issued solely to compel the complainant to supply documents regarding the hold departure order, insisting that the cancellation was automatic following the dismissal of the underlying criminal case.
Additional hearsay evidence from his wife and court clerks attempting to explain irregularities in the filing or stamping of the Motion to Quash and the Cancellation Order.

The subpoena was issued on October 23, 1997, after the cancellation order had been purportedly issued on April 30, 1997, raising doubts about the judge’s intent.
It was determined that, since the case had already been transmitted to the Provincial Prosecutor, Judge Lantin’s authority to issue subpoenas was legally null.

Evidence indicated that both the Motion to Quash the Hold Departure Order and the Order of Cancellation were typewritten by Judge Lantin and not properly filed as official court documents (e.g., absence of court employee initials and stamps).
The cancellation order was issued despite Judge Lantin lacking jurisdiction after the records had been forwarded to the Provincial Prosecutor.

The money used in the entrapment operation was recovered from a left drawer of Judge Lantin’s table, corroborated by multiple NBI agents.
Respondent’s contradictory statements regarding the handling and discovery of the money further complicated his version of events.

In view of the serious allegations against Judge Lantin, he was placed under preventive suspension pending further investigation.
Justice Narciso Atienza, consultant of the Office of the Court Administrator, conducted an exhaustive investigation resulting in a 24-page report and recommendations for disciplinary action.
The investigation and subsequent evidentiary findings led to the conclusion that Judge Lantin committed grave misconduct and acted outside his jurisdiction.

Whether Judge Lantin’s conduct in handling the hold departure order, issuing an illegal subpoena, and preparing cancellation documents amounted to entrapment or the planting of evidence.

Whether the issuance of the subpoena by Judge Lantin was lawful given that the case records had already been transmitted to the Provincial Prosecutor and his court no longer held jurisdiction.
Whether the manner in which the Motion to Quash and the Order of Cancellation were prepared indicated a deliberate attempt to extort money from the complainant.
Whether the recovery of the marked money from one of the drawers of his table can be considered evidence of his involvement in bribery and misconduct.

Entrapment: A situation where the criminal intent originates in the mind of the law enforcement officer, who facilitates the commission of the offense.
Planting of Evidence: An illegal act whereby evidence is deliberately placed to incriminate an innocent person.
The issue was further clarified by distinguishing that if the bribery allegations were the result of entrapment rather than the planting of evidence, accountability is directed towards the authorities who facilitated the setup, but here, the focus is on the misconduct and abuse of authority by Judge Lantin.