G.R. No. 7015 - People vs. Bengson

Jose Bengson had long served as the justice of the peace in the municipality of Urdaneta, Province of Pangasinan.
For several years, he functioned in his capacity alongside Francisco Austria, his clerk (or escribiente), who worked without receiving any salary.
Prior to the incident, the defendant had dismissed Francisco Austria from his position as clerk.

In or about October 1907, while conducting a preliminary investigation concerning the theft of carabaos belonging to Benigno Lucero and Esteban Larosa, the defendant was involved in handling the case.
Carabaos initially reported as stolen were later found by the police and identified as belonging to the respective owners.
A decision was made to remand the record of the investigation to the Court of First Instance of Pangasinan, whereby original documents belonging to the owners were required to accompany the record.

The complaint alleged that, as justice of the peace, the defendant demanded and exacted from each owner the sum of P6 before returning copies of the documents (Exhibits A and B) necessary for the remand of the case.
It was claimed that when the carabao owners complied by paying P6 each, the defendant then refused to issue receipts for these payments.
The offense was charged under article 399, in connection with articles 534 and 535, No. 1 of the Penal Code, defining the crime of illegal exaction.

The defendant denied that he personally demanded or received any money from the carabao owners, alleging instead that his dismissed clerk, Francisco Austria, was responsible for collecting the sum.
Testimonies from Benigno Lucero and Esteban Larosa affirmed that they each paid P6 to the defendant under the circumstances described in the complaint.
Credible witnesses substantiated the fact that nearly a year later (in 1908), a complaint was filed against Francisco Austria for the same alleged illegal exaction, suggesting a pattern possibly motivated by personal vendetta.
Exhibits A and B, which included copies of the documents and court orders, contained inconsistencies such as the presentation of signatures by cross, thereby casting doubt on the credibility of the complaint.

The defendant also noted that, prior to the trial related to the present case, charges had been preferred against him for administrative investigation.
He contended that Francisco Austria had maliciously instigated not only the present criminal action but also other administrative charges to prejudice him.
The inconsistencies in the allegations—in particular, the earlier complaint against Austria—raised questions about the true motive behind the current charges, suggesting they might have been aimed solely at annoying and prejudicing the defendant.

Whether the evidence presented sufficiently proves that the defendant, as justice of the peace, personally demanded and received P6 from the carabao owners in connection with the copying of their documents.

Whether the crime committed by the defendant should be categorized as illegal exaction, or if, as alleged by the defendant, the offense actually pertained to actions by his clerk, Francisco Austria.

Whether the inconsistencies and the existence of a prior complaint against Francisco Austria undermine the credibility of the current charge and point to a motive of harassment against the defendant.