Title
Government of Hong Kong Special Administrative Region vs. Munoz
Case
G.R. No. 207342
Decision Date
Nov 7, 2017
HKSAR sought Muñoz's extradition for fraud and bribery charges. SC denied, citing dual criminality rule unmet for bribery charge, as no equivalent crime exists in PH.

Case Summary (G.R. No. 207342)

Applicable Law and Framework

The analysis is based on the 1987 Philippine Constitution given the decision date of 2017. The pertinent law is the RP-Hong Kong extradition treaty, specifically Article 2 imposing the dual criminality rule, which requires that offenses subject to extradition must be punishable by imprisonment or detention exceeding one year under the laws of both jurisdictions.

Legal Issues: Rule of Specialty and Dual Criminality

The principle of specialty in international law limits surrender to only those offenses specified in the extradition treaty. Additionally, the dual criminality rule demands that the offense must be punishable in both requesting and requested states under comparable laws. The core issue was whether the respondent could be extradited for the crime of accepting an advantage as an agent, in addition to seven counts of conspiracy to defraud.

Court's Resolution on Extraditable Offenses

The Court held that Juan Antonio Muaoz could only be extradited for the seven counts of conspiracy to defraud, which were deemed public sector offenses covered by the treaty. However, the offense of accepting an advantage as an agent was classified as private sector bribery under Hong Kong law, and thus did not satisfy the dual criminality requirement since the Philippine law’s equivalent did not cover this crime in the same context.

Petitioner's Motion for Reconsideration and Arguments

The petitioner sought reconsideration to include the crime of accepting an advantage as an agent in the extraditable offenses, citing a ruling by the HKSAR Court of Final Appeal in B v. The Commissioner of the Independent Commission Against Corruption. This ruling allegedly interpreted "agent" in the Prevention of Bribery Ordinance (POBO) to include public servants in foreign jurisdictions. The petitioner’s request was denied due to failure to comply with evidentiary rules regarding foreign judgments.

Evidence and Judicial Notice of Foreign Rulings

The Court clarified that judicial notice of foreign laws and judgments is not automatic in Philippine courts and must be properly proven through official publications or authenticated copies as required by the Rules of Evidence. The petitioner failed to present adequate proof or official documentation of the foreign case cited, rendering the claim inadmissible.

Expert Testimonies and Nature of the Offense

Qualified legal experts from Hong Kong, including senior counsel and a senior assistant director of prosecutions, testified before the trial court that the offense under Article 9 of POBO was a private sector offense. These expert opinions supported the conclusion that the dual criminality rule was not met concerning the bribery offense for which extradition was sought.

Procedural and Timeliness Considerations

The petitioner was remiss in not timely and properly informing the Court of the pertinent Hong Kong case law during the earlier stages of the appeal. The motion for reconsideration only raised the matter belatedly, which undermined its relevance and applicability. The absence of proper evidence further justified the Court’s refusal to co

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