Case Digest (G.R. No. 236848)
Facts:
- Mangulabnan v. People involves Candelaria De Mesa Mangulabnan, a court interpreter, who was convicted of Direct Bribery under Article 210 of the Revised Penal Code.
- The case began with an Information charging Mangulabnan and Rodrigo R. Flores, the Presiding Judge of the MTCC, Branch 2, City of San Fernando, Pampanga.
- They were accused of demanding and receiving P20,000.00 from Dario Manalastas, a party to an election protest case, in exchange for a favorable decision.
- The alleged events occurred around March 1998 in San Fernando, Pampanga.
- Executive Judge Adelaida Ala-Medina initially investigated the administrative complaints against Judge Flores and Mangulabnan.
- Mangulabnan was found to have acted as a conduit for Judge Flores in receiving the bribe.
- Mangulabnan was suspended for one year, and the case was referred to the Office of the Ombudsman for further investigation.
- An Information was filed, and during the trial at the Sandiganbayan, the prosecution relied on documentary evidence from the administrative case.
- Mangulabnan waived her right to present evidence.
- The Sandiganbayan found her guilty, sentencing her to imprisonment and a fine, with special temporary disqualification from holding public office.
- Mangulabnan's motion for reconsideration and/or to reopen the case was denied, leading her to file a petition for review on certiorari before the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court denied the petition and affirmed the Sandiganbayan's Decision dated October 6, 2017, along with the Resolution dated January 15, 2018.
- The Court upheld Mangulabnan's conviction for Direct Bribery under Article 210 of the Revised Penal Code....(Unlock)
Ratio:
- The Supreme Court found that the Sandiganbayan correctly convicted Mangulabnan based on the established elements of Direct Bribery under Article 210 of the Revised Penal Code.
- The elements include: (a) the offender is a public officer; (b) the public officer accepts an offer or promise or receives a gift or present by himself or through another; (c) the offer or promise is accepted or the gift or present is received with a view to committing a crime, or in consideration of an unjust act, or to refrain from doing something which is his official duty to do; and (d) the act is connected with the performance of the public officer's official duties.
- Mangulabnan and Judge Flores were public officers, with Mangulabnan acting as a middleman in receiving P20,000.00 from Manalastas and delivering it to Judge Flore...continue reading
Case Digest (G.R. No. 236848)
Facts:
The case of Mangulabnan v. People involves petitioner Candelaria De Mesa Mangulabnan, a court interpreter, who was convicted of Direct Bribery under Article 210 of the Revised Penal Code. The case originated from an Information charging Mangulabnan and Rodrigo R. Flores, the Presiding Judge of the Municipal Trial Court in Cities (MTCC), Branch 2, City of San Fernando, Pampanga, with demanding and receiving P20,000.00 from Dario Manalastas, a party to an election protest case, in exchange for a favorable decision. The events took place around March 1998 in San Fernando, Pampanga. The administrative complaints against Judge Flores and Mangulabnan were initially investigated by Executive Judge Adelaida Ala-Medina, who found that Mangulabnan acted as a conduit for Judge Flores in receiving the bribe. Consequently, Mangulabnan was suspended for one year, and the case was referred to the Office of the Ombudsman (OMB) for further investigation, leading to the filing of the Information. During the trial at the Sandiganbayan (SB), the prosecution relied on documentary evidence from the administrative case, and Mangulabnan waived her right to present evidence. The SB found her guilty and sentenced her to imprisonment and a fine, with special temporary disqualification from holding public office. Mangulabnan's motion for reconsideration and/or to reopen the case was denied, prompting her to file a petition for review on certiorari before the Supreme Court.
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