G.R. No. 236848 , June 08, 2020
Candelaria De Mesa Mangulabnan, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner Candelaria De Mesa Mangulabnan, a Court Interpreter and Chairman of the Revision Committee of the Municipal Trial Court in Cities (MTCC) Branch 2, San Fernando, Pampanga, was charged with Direct Bribery under Article 210 of the Revised Penal Code. The Information alleged that in or about March 1998, she conspired with Presiding Judge Rodrigo R. Flores by demanding and receiving P20,000.00 from Dario Manalastas, a party in an election protest case pending before their court, in consideration for a decision favorable to Manalastas. The charge originated from an administrative complaint filed by the opposing party, Alberto Guinto, which was investigated by Executive Judge Adelaida Ala-Medina. Judge Medina’s report found that Judge Flores borrowed P20,000.00 from Manalastas, which Mangulabnan received as a middleman. The Supreme Court, in a prior administrative resolution, suspended Mangulabnan for one year and referred the matter to the Office of the Ombudsman, which then filed the criminal case. During the trial before the Sandiganbayan, the prosecution presented only documentary evidence from the administrative case, the due execution of which was stipulated upon by the parties. Mangulabnan waived her right to present evidence. The Sandiganbayan convicted her.

ISSUE

Whether or not the Sandiganbayan correctly convicted Mangulabnan of the crime of Direct Bribery under Article 210 of the Revised Penal Code.

RULING

Yes, the Sandiganbayan correctly convicted Mangulabnan. The Supreme Court found that all elements of Direct Bribery were proven beyond reasonable doubt: (a) Mangulabnan was a public officer; (b) she received a gift (P20,000.00) through her mediation for Judge Flores; (c) the amount was given in consideration for the rendition of a judgment favorable to Manalastas, which was an unjust act; and (d) the act related to the official duties of Judge Flores. Conspiracy between Mangulabnan and Judge Flores was established by the findings in the administrative case and by Mangulabnan’s own admission in a related civil case that she received the money and delivered it to Judge Flores, who ordered the release of the decision only after receiving it. The Court also held that the Sandiganbayan properly considered the stipulated documentary evidence from the administrative proceedings in its independent determination of guilt. Mangulabnan’s right to due process was not violated as she was given the opportunity to present evidence but waived it. The petition was denied for lack of merit.