Case Digest (G.R. No. 136266) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Eutiquio A. Peligrino v. People of the Philippines (G.R. No. 136266, August 13, 2001), petitioner Eutiquio A. Peligrino, a Bureau of Internal Revenue (BIR) Examiner II and member of the Special Project Committee in Region IV-A, was charged under Section 3(b) of the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019) for having demanded and received P200,000 from Dr. Antonio N. Feliciano in connection with the doctor’s alleged P500,000 tax deficiency for calendar years 1988–1989. The Information, filed on October 17, 1991 and later amended to include Supervisor Atty. Buenaventura V. Buenafe as co-accused, alleged that P51,858.57 of the amount was to be applied to BIR liabilities via Authority to Issue Payment Order (ATIPO) while the balance constituted a payoff. After Dr. Feliciano sought NBI assistance, an entrapment operation on October 15, 1991 recovered P3,000 in marked bills from Peligrino’s possession, and forensic examination revealed fluorescent powder on his Case Digest (G.R. No. 136266) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Petitioner Eutiquio A. Peligrino, then Examiner II of BIR Region IV-A, and co-accused Atty. Buenaventura V. Buenafe, Supervisor of the same region, were charged under Section 3(b) of RA 3019 for demanding and receiving P200,000 from Dr. Antonio N. Feliciano in connection with a tax assessment.
- Information filed October 17, 1991 (amended February 25, 1992). Both pleaded not guilty at Sandiganbayan arraignment (August 28, 1992). After trial, the Sandiganbayan (First Division) on August 24, 1998 convicted Peligrino and acquitted Buenafe; Motion for Reconsideration denied November 16, 1998.
- Prosecution Evidence
- Dr. Feliciano complained to NBI, which marked P3,000 in fluorescent powder and arranged entrapment. On October 15, 1991, Peligrino appeared at Feliciano’s clinic, received a brown envelope containing the marked money, then was arrested by NBI agents.
- Inventory of seized items from Peligrino included Prudential check, BIR Authorities to Issue Payment Orders, assessment worksheets, letters of authority, and the envelope with bogus money. Forensic Chemist found fluorescent powder on Peligrino’s person.
- Defense Evidence
- Both accused denied extortion. Buenafe testified he served a valid letter of authority and merely discussed assessment figures; Peligrino testified the envelope was thrust at him by unidentified persons and he resisted holding it. Both claimed no demand or receipt occurred.
- They offered affidavits, BIR certifications, letters and memoranda to impeach Feliciano’s character and to demonstrate their regular official conduct.
Issues:
- Whether the Sandiganbayan erred in finding that petitioner demanded and received the envelope with the boodle money.
- Whether the conviction relied unjustly on the lone testimony of Dr. Feliciano, an allegedly discredited witness.
- Whether petitioner was denied equal protection of the law given his co-accused’s acquittal.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)