Title
People vs. Bengson
Case
G.R. No. 7015
Decision Date
Aug 19, 1912
Justice of the peace accused of illegal exaction; acquitted due to insufficient evidence, prior complaint against clerk, and reasonable doubt.
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Case Digest (G.R. No. 7015)

Facts:

Background of the Case

  • The defendant, Jose Bengson, was the justice of the peace in Urdaneta, Pangasinan, during the relevant period.
  • A preliminary investigation was conducted regarding the theft of carabaos belonging to Benigno Lucero and Esteban Larosa.
  • The carabaos were recovered and held for safekeeping during the investigation.

Allegations of Illegal Exaction

  • The complaint alleged that Bengson demanded P6 from each of the carabao owners (Lucero and Larosa) to return their animals and avoid sending the case to the Court of First Instance in Lingayen.
  • Lucero and Larosa paid the amount but were denied receipts for the payments.

Defendant’s Defense

  • Bengson denied demanding or receiving any money from Lucero and Larosa.
  • He claimed that his former clerk, Francisco Austria, collected the money without his knowledge or consent.

Evidence Presented

  • Lucero and Larosa testified that they paid Bengson directly.
  • Francisco Austria testified that the payments were made to Bengson.
  • Defense witnesses presented evidence (Exhibits A and B) showing that Lucero and Larosa had previously filed a complaint against Austria for estafa, alleging that Austria had illegally collected the same P6 from them.

Prior Complaint Against Austria

  • Lucero and Larosa denied filing a complaint against Austria, but defense witnesses and documentary evidence (Exhibits A and B) confirmed the existence of such a complaint.
  • The complaint against Austria was filed nearly a year before the current case against Bengson.

Defendant’s Allegations of Malice

  • Bengson claimed that Austria, whom he had dismissed as his clerk, orchestrated the charges against him out of malice.

Issue:

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Ruling:

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Ratio:

  1. Insufficient Evidence of Illegal Exaction: The Court found that the evidence presented by the prosecution did not conclusively prove that Bengson demanded or received the P6 from Lucero and Larosa. The testimony of the complainants was contradicted by prior actions (the complaint against Austria) and documentary evidence.
  2. Prior Complaint Against Austria: The existence of a prior complaint against Francisco Austria for the same alleged crime cast doubt on the credibility of Lucero and Larosa’s claims against Bengson. The Court inferred that the present case was likely brought to harass Bengson.
  3. Defendant’s Defense Credible: Bengson’s defense that Austria acted independently and maliciously was supported by the evidence, including the prior complaint and the dismissal of Austria as his clerk.
  4. Reasonable Doubt: The inconsistencies and contradictions in the evidence created reasonable doubt about Bengson’s guilt, warranting his acquittal.


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