Case Summary (G.R. No. 232199)
Chronology of Events
On April 21, 1976, Encarnacion lodged a sworn complaint with the Secretary of Justice against Peralta, alleging graft and corruption along with ignorance of the law, gross inefficiency, and abuse of authority. The Secretary of Justice subsequently forwarded the complaint to the Supreme Court. On September 30, 1976, the Court dismissed the charges concerning ignorance of the law, inefficiency, and abuse of authority for being premature. The Court referred the graft and corruption charge for investigation by the Executive Judge of Camarines Sur.
Investigative Findings and Recommendations
Following the investigation, the Executive Judge reported a lack of substantial evidence to support Encarnacion’s allegations. The investigation concluded that there was no credible proof that Peralta received the alleged bribe of P60.00. The testimony of key witnesses, including one identified as Simeon Hernandez, was found to lack evidentiary value, and it was suggested that the complaint was retaliatory in nature, arising from Encarnacion's perceived personal grievances against Peralta.
Corroborated Evidence and Inconsistencies
The Acting Judicial Consultant reinforced the Executive Judge's findings, indicating that the evidence presented was insufficient to corroborate that Peralta solicited or received P60.00 from Encarnacion. Notably, witness accounts contradicted each other, including discrepancies about the demand for P200.00 by Peralta in the Garden Restaurant, suggesting it was a coordinated narrative rather than a verified instance of misconduct.
Legal Context and Conclusion
Upon reviewing the complete records and evidence, the Sup
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Background of the Case
- On April 21, 1976, Aquilino Encarnacion, a barangay captain, farm manager, and attorney-in-fact of a former Congressman, filed a sworn complaint against Crispin I. Peralta, deputy provincial sheriff of Camarines Sur.
- The complaint charged Peralta with (1) graft and corruption, and (2) ignorance of the law, gross inefficiency, and abuse of authority.
- The Secretary of Justice forwarded the complaint to the Supreme Court, which dismissed the charges regarding ignorance of the law, inefficiency, and abuse of authority as premature.
Court Proceedings
- On September 30, 1976, the Supreme Court referred the graft and corruption charge against Peralta to the Executive Judge of Camarines Sur for investigation, report, and recommendation.
- The Executive Judge conducted hearings and later submitted a report recommending the dismissal of the case, stating insufficient evidence to support the allegations against Peralta.
- The Acting Judicial Consultant also recommended dismissal, highlighting the lack of substantive evidence regarding the graft cha