Title
Pueblo de las Islas Filipinas vs. Ang Tex
Case
R.G. No. 38779
Decision Date
Aug 30, 1933
Appellant Ang Tex offered P1.50 to a detective to release his chauffeur, leading to his conviction for attempted bribery, later modified to *arresto menor* and a fine.
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Case Digest (R.G. No. 38779)

Facts:

  1. Incident Details:

    • The appellant, Ang Tex, rented a truck (No. TH-530 Nueva Ecija) driven by chauffeur Mariano Ronquillo.
    • On October 18, 1932, at around 5:30 PM, the truck was traveling along San Marcelino Street in Manila.
    • The truck was overloaded, leading to the arrest of the chauffeur, Mariano Ronquillo, by Detective Pedro Manuel.
  2. Bribery Attempt:

    • Ang Tex offered Detective Pedro Manuel P1.50 to release the chauffeur.
    • Detective Manuel ignored the initial offer.
    • Ang Tex persisted, offering the money again, suggesting it would be better for Manuel to keep the money rather than let it go to the government.
    • Detective Manuel arrested Ang Tex and brought him to the police station.
  3. Legal Proceedings:

    • Mariano Ronquillo was charged and convicted for violating the Revised Ordinances of Manila.
    • Ang Tex was charged with attempted bribery and convicted by the Court of First Instance of Manila.
    • He was sentenced to pay a fine of P50, with subsidiary imprisonment in case of insolvency, and the confiscation of the bribe amount.
  4. Appellant’s Defense:

    • Ang Tex admitted offering P1.50 but claimed it was part of P5.00 that Detective Manuel had demanded from him.
    • The court found this defense unproven.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Elements of Attempted Bribery:

    • The crime of bribery requires an offer or promise of something of value to a public officer in exchange for an act related to their official duties.
    • Attempted bribery occurs when the offer is made but not consummated.
  2. Credibility of Witnesses:

    • The trial court’s assessment of witness credibility is entitled to great weight unless there is a clear showing of error.
    • The court found Detective Manuel’s testimony more credible than Ang Tex’s defense.
  3. Penalty Modification:

    • Under Articles 212 and 210, Paragraph 3, of the Revised Penal Code, the penalty for bribery is arresto mayor in its maximum degree and a fine not less than the value of the offer and not more than three times its value.
    • Since the crime was only attempted, the penalty was reduced to two degrees lower, resulting in arresto menor and a fine of P3.00.


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