G.R. No. 222861. APRIL 23, 2018.
PO2 JESSIE FLORES Y DE LEON, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

On June 26, 2000, private complainant Roderick France figured in a vehicular accident in Quezon City. Petitioner PO2 Jessie Flores, a traffic enforcer, investigated, confiscated France’s driver’s license, and issued a Traffic Violation Receipt (TVR). Flores told France to return after two days and prepare ₱2,000.00 for the license’s return. Suspicious, France reported the incident to the Presidential Anti-Organized Crime Task Force (PAOCTF), which organized an entrapment. On June 29, 2000, France, with marked money, met Flores at the police station. Flores directed France to drop the money into a drawer, counted it, and was subsequently arrested by the PAOCTF team.
The defense presented a different version, alleging a frame-up. Flores claimed he had properly confiscated the license and directed France to settle the violation at the Quezon City Redemption Center. He asserted that France, upon returning on June 29, surreptitiously placed the money in his drawer while he was in the comfort room, leading to his unwarranted arrest.

ISSUE

Whether the Court of Appeals erred in affirming petitioner’s conviction for Simple Robbery (Extortion) under Article 294(5) of the Revised Penal Code.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court emphasized that factual findings of the trial court, especially when affirmed by the CA, are generally binding and conclusive. It found no reason to deviate from these findings, as the trial court was in the best position to assess witness credibility. The prosecution successfully established all elements of the crime: (1) petitioner took personal property (₱2,000.00); (2) the taking was with intent to gain; (3) it was done without the owner’s consent; and (4) it was accomplished by means of intimidation arising from petitioner’s abuse of his official position as a police officer.
The Court rejected petitioner’s defense of denial and frame-up, which are inherently weak and cannot prevail over the positive and categorical testimony of the complainant, which was corroborated by the PAOCTF operatives. The detailed account of the entrapment operation, including the recovery of the marked money from petitioner’s drawer and the ultraviolet powder on his hands, constituted proof beyond reasonable doubt. The act of demanding money as a condition for returning the confiscated license constituted the intimidation necessary for robbery by extortion, exploiting his official authority to instill fear and compel payment.