Case Summary (G.R. No. L-56013)

Case Background and Charges

• Liwanag Aguirre, the petitioner, was charged with direct bribery under Article 210 of the Revised Penal Code.
• The Information alleged that on November 24, 1978, Aguirre, as an Acting Deputy Sheriff of the National Labor Relations Commission (NLRC), unlawfully demanded and obtained ₱50 from Hermogenes Hanginon, an employee of Guardsman Security Agency.
• This payment was purportedly made in exchange for Aguirre's decision to refrain from executing a Writ of Execution against the security agency, which was under a final judgment from the NLRC.

Trial and Conviction

• Aguirre pleaded not guilty, and the case proceeded to trial.
• The Sandiganbayan convicted Aguirre based on the evidence presented, particularly the testimony of Hanginon, the sole prosecution witness.
• The court acknowledged the mitigating circumstance of voluntary surrender and sentenced Aguirre to two months and one day of arresto mayor, along with additional penalties including a fine and special temporary disqualification.

Grounds for Appeal

• Aguirre appealed the conviction, arguing that the evidence was insufficient to prove his guilt beyond a reasonable doubt.
• He contended that the Sandiganbayan erred by relying on the uncorroborated testimony of Hanginon, the only witness for the prosecution.

Legal Standards for Review

• In certiorari proceedings under Rule 45, the Supreme Court typically does not disturb the lower court's findings of fact or credibility assessments unless there are substantial overlooked facts.
• The presumption of innocence requires that a conviction must be supported by proof beyond a reasonable doubt, which is the burden of the prosecution.

Evaluation of Witness Testimony

• The Sandiganbayan justified its reliance on Hanginon’s testimony, asserting its credibility despite its uncorroborated nature.
• The court noted that Hanginon’s demeanor and the lack of motive to fabricate his testimony lent credibility to his account.

Concerns Regarding Evidence

• The Supreme Court highlighted that the prosecution's reliance on a single witness does not inherently render the evidence insufficient for conviction.
• However, the Court expressed skepticism regarding the circumstances of the alleged bribery, questioning the logic of Aguirre demanding a bribe from a low-level employee without authority or funds.

Doubts About the Prosecution...continue reading

Case Syllabus (G.R. No. L-56013)

Case Background

• Petitioner Liwanag Aguirre contests a decision by the Sandiganbayan which found him guilty of direct bribery under Article 210 of the Revised Penal Code.
• The Information charged Aguirre with unlawfully demanding and obtaining PHP 50 from Hermogenes Hanginon, an employee of Guardsman Security Agency, as a bribe to refrain from executing a writ against the agency.
• The alleged incident occurred on November 24, 1978, in Davao City, where Aguirre was serving as an Acting Deputy Sheriff of the National Labor Relations Commission (NLRC).

Trial Proceedings

• Aguirre pleaded not guilty, and the case proceeded to trial based on the presented Information and evidence.
• The Sandiganbayan convicted Aguirre, recognizing mitigating circumstances of voluntary surrender and no aggravating factors.
• The sentence included two months and one day of arresto mayor, six years and one day of special temporary disqualification, a fine of PHP 50, and indemnification to Hanginon for the same amount.

Grounds for Appeal

• Aguirre's appeal centers on the argument that the prosecution's evidence was insufficient to prove his guilt beyond a...continue reading