Facts:

• In "People vs. Horca" (G.R. No. 2676), decided on March 31, 1906, Eustaquio Horca faced charges of robbery.
• The incident took place in Jaro, Leyte.
• Narciso Rile was detained by Horca, who was the municipal president.
• During Rile's detention, his wife brought 130 pesos, which Rile handed over to Horca.
• Three days after the arrest, Rile was released.
• The lower court ruled the incident as robbery.
• The Attorney-General argued it was a case of threats under Article 494, number 1, of the Penal Code.

Issue:

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Ruling:

• The Supreme Court dismissed the robbery charge.
• Ordered the filing of a new complaint against Horca for bribery.
• Concluded that setting a prisoner fre...(Unlock)

Ratio:

• The transaction involved Horca, a public official, receiving money from Rile and then releasing him.
• The crucial issue was the bribery by a public official, irrespective of whether Rile paid to escape imprisonment or for another reason.
• Determined it was not robbery or threats due to the absence of violence or deceit.
• Horca promised to release Rile in exchange for money and fulfilled that promise, which is bribery.
• Emphasize...continue reading