Title
People vs Gloria
Case
G.R. No. 1740
Decision Date
Mar 27, 1905
Julio Gloria attempted bribery by offering 200 pesos to a provincial treasurer to influence an election protest, deemed an overt act under the Penal Code.

Case Summary (G.R. No. L-13370)

Charges and Events Leading to the Case

Gloria was accused of making an offer to the treasurer of the province, promising 200 pesos in exchange for support regarding the electoral protest. The events surrounding this case were uncontested, and the pivotal legal question was whether Gloria’s actions constituted an offense as defined within the applicable Penal Code provisions.

Legal Question and Appellant's Argument

The primary argument raised by the appellant, Gloria, contended that his offer constituted a mere proposal rather than an actual attempt to commit bribery. According to Gloria, under Article 4 of the Penal Code, proposals to commit crimes are penalized only when specific authority exists therein, which he maintained was not the case for bribery.

Court's Analysis of Attempt

The court held that Gloria’s offer amounted to an "attempt" as defined under Article 3 of the Penal Code. This article states that an attempt is established when an individual takes direct and overt actions towards committing a crime but fails to complete all necessary actions to consummate the crime due to reasons outside of their own voluntary choices. In this instance, Gloria’s act of offering money was deemed an overt act sufficient to qualify as an attempt at bribery.

Conclusion and Court's Decision

The court concluded that Gloria's proposal was not merely a suggestion but an actionable step towards committing the crime of bribery. The refusal of the proposed bribe by th

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