G.R. No. 147578-85 - Balderama vs. People

Case Summary (G.R. No. 147578-85)

Petitioners

– Rolando L. Balderama
– Rolando D. Nagal
Both served as LTO enforcement officers assigned to inspect and apprehend taxi drivers for regulatory violations.

Respondents

– People of the Philippines (through the Office of the Ombudsman and the Special Prosecutor)
– Juan S. Armamento (private complainant and taxi operator)

Key Dates

– February 15, 1992: Alleged first offer to refrain from inspections in exchange for “protection money.”
– July 14, 1992: Impounding of one taxi unit for purported meter defect.
– June 30, 1994: Arraignment and not‐guilty pleas.
– March 5, 1999: Death of co‐accused Cresencio de Jesus.
– November 17, 2000: Sandiganbayan decision convicting petitioners.
– March 20, 2001: Sandiganbayan denial of motions for reconsideration and new trial.
– April 20, 2007: Finality of related petition for review (Lubrica).
– January 28, 2008: Supreme Court decision under review.

Applicable Law

– 1987 Philippine Constitution (post‐1990 decisions)
– Rule 45, 1997 Rules of Civil Procedure, as amended
– Revised Penal Code, Article 210 (Direct Bribery)
– Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), Section 3(e)
– Doctrine on binding findings of fact and treatment of recantations

Facts of the Case

Acting on complaints of discriminatory service, an LTO “Flying Squad” inspected Armamento’s taxis. On July 14, 1992, they impounded one unit for an alleged defective meter, which LTO tests later proved functional. Armamento claimed that, beginning February 15, 1992, the squad had been extorting P300 semi-monthly in exchange for foregoing official inspections. After he defaulted, he filed bribery and RA 3019 complaints with the Ombudsman.

Informations Filed

– Criminal Cases Nos. 20669–20677: Each charged petitioners and co-accused with direct bribery under RPC Article 210 for soliciting and receiving P300 to refrain from inspections.
– Criminal Case No. 20678: Charged petitioners with violation of RA 3019 Sec. 3(e) for maliciously impounding Armamento’s taxi, causing undue injury through evident bad faith.

Trial Proceedings

All accused pleaded not guilty on June 30, 1994. The cases were consolidated; petitioners and co-accused were suspended pendente lite. Following the death of Cresencio de Jesus in 1999, proceedings continued against Balderama, Nagal, and Cipriano Lubrica.

Sandiganbayan Findings

In its November 17, 2000 Decision, the Sandiganbayan:

Convicted petitioners and Lubrica of direct bribery in seven of nine counts, sentenced to 4 years 2 months to 5 years 4 months 20 days at the range of prision correccional, plus special temporary disqualification, P300 fine, and restitution.
Acquitted them in two counts for lack of proof.
Convicted them under RA 3019 Sec. 3(e) for the impounding incident, imposing 6 years 1 month to 10 years 1 day imprisonment, perpetual public-office disqualification, and P1,500 indemnity.
Motions for reconsideration (arguing absence of conspiracy) and for new trial (based on Armamento’s post-conviction recantation affidavit) were denied on March 20, 2001.

Issues on Supreme Court Review

Whether petitioners’ guilt was proven beyond reasonable doubt for:

Direct bribery under RPC Article 210.
Malicious injury under RA 3019 Section 3(e).
Validity of inferred conspiracy and disregard of the complainant’s recantation.

Direct Bribery Liability

Article 210 elements—public officer status; soliciting/receiving gift; consideration for refraining from official duty; relation to office functions—were all established. Petitioners’ alibi and denial were unsubstantiated, affirming the Sandiganbayan’s finding of direct bribery in seven counts.

RA 3019 Section 3(e) Liability

The Court confirmed that petitioners, as public officers, in bad faith during official functions, caused undue injury by impounding Armamento’s taxi. All requisite elements—office relation, injury, and evident bad faith—were prese

Case Syllabus (G.R. No. 147578-85)

Procedural History

Two petitions for review on certiorari under Rule 45, 1997 Rules of Civil Procedure, as amended, were consolidated before the Supreme Court.
The petitions sought to reverse the Sandiganbayan’s Joint Decision dated November 17, 2000 in Criminal Cases Nos. 20669–20678 and its Resolution of March 20, 2001.
Petitioners Rolando L. Balderama (G.R. Nos. 147578–85) and Rolando D. Nagal (G.R. Nos. 147598–605) challenged convictions for direct bribery (Art. 210, RPC) and violation of Sec. 3(e), R.A. No. 3019.
Separate motions for reconsideration and new trial were filed before the Sandiganbayan; all were denied on March 20, 2001.
A related petition by co-accused Cipriano L. Lubrica was dismissed by the Supreme Court on February 26, 2007 for late filing.

Factual Background

Petitioners Balderama and Nagal were LTO officers in the Field Enforcement Division (“Flying Squad”), alongside Lubrica and Cresencio de Jesus.
Respondent Juan S. Armamento operated a ten-unit taxi fleet and complained of discriminatory, “a contrata basis” service by airport taxi drivers.
On July 14, 1992, the Flying Squad impounded one of Armamento’s taxis for an alleged defective meter; subsequent LTO inspection found the meter in proper working order, and the vehicle was released.
Aggrieved, Armamento filed on December 2, 1992 with the Ombudsman a complaint accusing the four officers of collecting “protection money” (P300 bi-monthly) in exchange for non-apprehension of his taxi units.

Charges and Informations

The Ombudsman filed nine Informations for:
• Direct bribery under Article 210, RPC (Criminal Cases Nos. 20669–20677)
• Violation of Section 3(e), R.A. No. 3019 (Criminal Case No. 20678)
Sample allegations: solicitation and receipt of P300 in consideration for refraining from official duty (Art. 210) and maliciously impounding the taxi, causing undue injury and bad faith (Sec. 3(e), R.A. No. 3019).

Trial Proceedings in the Sandiganbayan

Petitioners pleaded no