Case Summary (G.R. No. 251778)
Antecedents and Lower Court Findings
The Ombudsman found probable cause in August 2011 to charge Purugganan with direct bribery (₱50,000) and RA-3019 violation (demand of ₱300,000, receipt of ₱50,000). The RTC convicted him of both offenses in February 2017, sentencing him to indeterminate prison terms and fines.
Prosecution’s Evidence
• Complainant Avecilla recounted paying Purugganan to expedite his uncle’s land‐titling.
• Initial demand was ₱300,000, later reduced to ₱50,000.
• An NBI‐supervised entrapment at Jollibee East Avenue captured Purugganan accepting an envelope.
• NBI Agent Anire and LRA Director Encisa corroborated the transaction.
• Forensic testing showed no fluorescent powder on the accused’s hands; only the money, not the envelope, was dusted.
Defense Version
• Petitioner denied touching or seeing the money’s contents, insisting he was approached unsolicited.
• He testified that the envelope contained documents, not cash, and that he refused illicit dealings.
• He highlighted his administrative‐case exoneration for grave misconduct and lack of proof of demand or receipt.
RTC Joint Decision
The court held all elements of:
- Direct Bribery: public officer status; demand/receipt of gift; connection to official duties.
- RA-3019 Sec. 3(b): corrupt request/receipt in a government transaction.
Accordingly, Purugganan received incarceration and fines for both counts.
Sandiganbayan Ruling
The Sandiganbayan:
- Affirmed conviction for direct bribery (Crim. Case No. Q-11-171918).
- Reversed and set aside conviction for RA-3019 violation (Crim. Case No. Q-11-171919) due to failure to prove an indispensable element.
Issue on Review
Whether petitioner’s guilt for direct bribery was proven beyond reasonable doubt.
Supreme Court’s Analysis
- Appellate jurisdiction confined to legal questions; factual findings stand absent palpable absurdity.
- Direct bribery elements under Article 210 R.P.C. were satisfied:
a. He was a public officer.
b. He demanded and received a gift.
c. In exchange for performing an official act (expediting titling).
d. The act was connected to his duties. - The envelope’s placement, petitioner’s inquiry, and witness accounts established intent to receive.
- Absence of text‐message exhibits did not undermine proof; such electronic evidence may be proven by testimony.
- Administrative acquittal does not bar criminal liability when the underlying act is undisputed.
- Negative fluorescent test did not negate receipt, as the envelope was not dusted.
Penalty Modification
Under the Indeterminate Sentence Law:
- The medium term of prision correccional in its minimum period becomes th
Case Syllabus (G.R. No. 251778)
Procedural History
- Petition for Review on Certiorari under Rule 45 filed by Giovanni S. Purugganan seeking reversal of Sandiganbayan, Third Division Decision (November 6, 2019) and Resolution (February 10, 2020) in SB-18-A/R-0014 to 0015.
- Sandiganbayan partially granted petitioner’s appeal from the RTC Joint Decision (February 8, 2017), affirming conviction for Direct Bribery (Crim. Case No. Q-11-171918) and reversing conviction for violation of Section 3(b), RA 3019 (Crim. Case No. Q-11-171919), resulting in acquittal on the latter.
- Motion for Partial Reconsideration before the Sandiganbayan was denied for lack of merit and as pro forma.
- Petition raises purely questions of law, challenging the Sandiganbayan’s findings on essential elements of the offenses.
Factual Background
- August 24, 2011 Ombudsman Resolution (OMB-C-C-11-0540-H) found probable cause to charge petitioner with Direct Bribery (Art. 210, RPC, as amended) and violation of Section 3(b), RA 3019.
- Informations filed before RTC:
• Crim. Case No. Q-11-171918 – Direct Bribery: petitioner, Land Registration Authority (LRA) Examiner I, allegedly demanded and received ₱50,000 from Albert Avecilla in exchange for expediting issuance of an LRA Order to the Register of Deeds of La Union.
• Crim. Case No. Q-11-171919 – Section 3(b), RA 3019: same facts alleged as corrupt practice in relation to petitioner’s official functions.
Version of the Prosecution
- Private complainant Albert R. Avecilla recounted:
• October 22, 2010 RTC La Union decision ordering registration decree in favor of his uncle, Benjamin Ramos.
• July 2011 LRA inquiry: petitioner explained irregular boundaries and estimated 6–8 months processing; during lunch, petitioner offered to expedite process for ₱300,000.
• Subsequent text messages from petitioner inquiring about payment; agreed to ₱50,000 downpayment.
• Directed by NBI Agent Normando Anire to confirm meeting at Jollibee East Avenue on August 23, 2011, and to tell petitioner he had only ₱50,000.
• At Jollibee, petitioner had complainant place envelope with marked banknotes on the table; petitioner touched, pulled envelope close and peered inside; complainant then executed signal for entrapment.
• Two undercover NBI agents arrested petitioner, who was brought to the NBI office; complainant executed further sworn statement there. - Corroborated by NBI Agent Anire and LRA Director Porfirio Encisa Jr., who both confirmed complainant’s account.
- Forensic Chemist Calalo testified that only the money bills bore fluorescent powder; petitioner’s hands tested negative under UV li