Title
Pozar vs. Court of Appeals
Case
G.R. No. L-62439
Decision Date
Oct 23, 1984
An American citizen is acquitted of the crime of Corruption of a Public Official in the Philippines due to lack of evidence, as his act of providing money for necessary documentation during his probation application was deemed innocent and not criminal.
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Case Digest (G.R. No. L-62439)

Facts:

  • Gregory James Pozar, an American citizen and permanent resident of the Philippines, was charged with Corruption of a Public Official.
  • The incident occurred on December 17, 1979, in Angeles City, Philippines.
  • Pozar, while applying for probation after being convicted of less serious physical injuries and oral defamation, allegedly gave a P100 bill to Danilo Ocampo, the City Probation Officer.
  • The case was filed on July 22, 1980, in the City Court of Angeles City, Branch I, as Criminal Case No. CAT-326.
  • Pozar pleaded not guilty upon arraignment.
  • On May 15, 1981, the City Court found him guilty and sentenced him to three months and one day of imprisonment and public censure.
  • The decision was appealed to the Court of Appeals, which affirmed the lower court's ruling.
  • Pozar's motion for reconsideration was denied, prompting him to file a petition for review, arguing insufficient evidence of his guilt.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed the judgment of the lower courts and acquitted Gregory James Pozar.
  • The Court ruled that the act of ...(Unlock)

Ratio:

  • The Supreme Court found that the prosecution failed to prove beyond a reasonable doubt that Pozar intended to bribe the City Probation Officer.
  • Evidence showed Pozar needed to submit various documents for his probation application, including copies of his passport and visa.
  • The procedure for processing Pozar's application was unclear, and as a foreigner unfamiliar with the rules, Pozar's act of providing money for documentation expenses was understandable and innocent.
  • The Court emph...continue reading

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