G.R. No. 80511 - Costabella Corporation vs. Court of Appeals

Gregory James Pozar, an American citizen and permanent resident of the Philippines, was convicted by the City Court of Angeles City, Branch I, for less serious physical injuries and oral defamation.
On November 28, 1979, Pozar filed an application for probation with the Angeles City Probation Office.

December 7, 1979 – Assistant Probation Officer Primitiva Francisco interviewed Pozar, gave him a list of documentary requirements (barangay, police, court clearances; residence certificate; three ID pictures; court decision; complaint; recognizance or bail bond), and instructed him to report weekly.
December 10, 1979 – Probation Officer Danilo Ocampo required Pozar, as a foreigner, to submit xerox copies of his passport and visa; Pozar complied.

December 17, 1979 – Pozar brought to the office a sealed envelope addressed to Probation Officer Ocampo and gave it to clerk Ricardo Manalo for delivery.
December 19, 1979 – Manalo handed the envelope to Ocampo, who opened it in Manalo’s presence and found xerox copies of Pozar’s passport and visa with an inserted ₱100 bill (Serial No. BC530309). Ocampo remarked that “this is something bad,” kept the bill as evidence, and included the incident in the post-sentence investigation report prepared by Francisco.

May 15, 1981 – City Court found Pozar guilty of corruption of a public official (Art. 212, RPC in relation to Art. 211) and sentenced him to three months and one day of arresto mayor, public censure, and forfeiture of the ₱100 bill.
October 19, 1982 – Court of Appeals denied reconsideration and affirmed the conviction in toto.
December 21, 1982 – Pozar filed a petition for review with the Supreme Court alleging failure of the prosecution to prove guilt beyond reasonable doubt.

Whether the prosecution proved beyond reasonable doubt that Pozar acted with criminal intent to corrupt the probation officer.
Whether the insertion of the ₱100 bill constituted a bribe or was an innocent advance to defray photocopying expenses.
Whether the offense, as charged under Art. 212 (corruption of public official) in relation to Art. 211 (indirect bribery), was consummated or merely attempted when Ocampo refused or failed to accept the money.