G.R. No. L-58889 - Manipon, Jr. vs. Sandiganbayan

Nathaniel S. Manipon, Jr., a deputy sheriff of the Court of First Instance of Baguio City and Benguet, Branch IV, was assigned to enforce an order issued by the Minister of Labor dated October 31, 1979.
The order directed the execution of a labor arbiter’s decision in NLRC Case No. RB-1-C-1428-79, which ordered Harry Dominguez (a building contractor and then-mayor) to pay judgment creditors an amount of P2,720.00 with interest.

On November 9, 1979, Manipon sent a notice to the Commercial Bank and Trust (Comtrust) in Baguio City to garnish the bank accounts of Dominguez.
Despite being his official duty, Manipon failed to inform the labor arbiter of the garnishment or expedite the payment of the judgment, indicating an initial deviation from standard procedure.

On November 12, 1979, Dominguez sought Manipon’s assistance regarding the withdrawal from the garnished account, but Manipon denied the possibility immediately.
During a subsequent meeting on December 27, 1979, at the National Intelligence and Security Authority (NISA) office in Baguio City, Manipon suggested he “can remedy the withdrawal,” a statement that Dominguez interpreted as an offer to facilitate the withdrawal for a consideration.

In response to Manipon’s insinuation, Dominguez, along with NISA operatives including Sub-Station Commander Luisito Sanchez and other officials, devised an entrapment plan.
Preparations included assembling marked money amounting to P700.00 in fifty-peso bills (authenticated, xeroxed, and dusted with fluorescent powder).
On December 28, 1979, Dominguez went to Comtrust as planned; Manipon appeared with two companions (Deputy Sheriff Crisanto Flora and Baltazar Pacis) to lift the garnishment order.
Dominguez executed a withdrawal slip for P2,500.00, from which P300.00 was set aside before combining it with the P700.00 in marked money, resulting in a total of P1,000.00 handed over to Manipon.

Shortly after leaving the bank via Session Road, Manipon and his companions were accosted by Philippine Constabulary and NISA agents.
The P1,000.00 was seized from Manipon’s left breast pocket after he was subjected to an ultraviolet light test confirming the presence of fluorescent powder.
Despite the strong evidence, Manipon remained silent and refused to provide a statement, later filing his sheriff’s return unsatisfied on February 20, 1980—well beyond the prescribed 30-day period.
Initially charged under Presidential Decree No. 46 for demanding and receiving money for an official favor, the charge was amended on February 16, 1981, to direct bribery under the Revised Penal Code.

Manipon contended that the P1,000.00 was a payment toward a novated judgment debt, asserting that Dominguez had agreed to a partial payment so that creditors, represented by Longog Tabek, would accept a lesser amount.
The alleged agreement was entirely verbal, lacking any supporting written memorandum. A temporary receipt later produced by Manipon was viewed as a last-minute fabrication intended to support his defense.
Testimonies from his co-sheriff Crisanto Flora and creditor Longog Tabek were found to be unreliable or biased, further undermining the defense’s version.
In addition, a prior episode in which Manipon and Flora executed garnishment against vehicles owned by Dominguez was cited as evidence of an existing grudge, thus questioning the credibility of any purported novation.

Whether Manipon’s actions constitute the crime of direct bribery under Article 210 of the Revised Penal Code.

Did Manipon, as a public officer, receive a gift or promise directly (or through intermediaries) in exchange for failing to execute an official duty?
Was there any legitimate basis to consider the P1,000.00 received as a payment in partial satisfaction of a judgment debt rather than a bribe?

The admissibility of the evidence obtained through the seizure of the P1,000.00 despite the absence of a valid search warrant.

Could the warrantless seizure be justified under the recognized exceptions, such as a search incident to a lawful arrest or seizure in plain view?
Do the facts surrounding the interception and signaling by law enforcement validate the evidence obtained?

The credibility and weight to be given to the conflicting testimonies and documentary evidence.

Is the defense’s claim of a novated agreement, supported by the allegedly concocted temporary receipt, credible?
How does the court assess the credibility of the prosecution’s witnesses compared to the defense’s recourse to conflicting and tardy evidence?