G.R. No. 251778 . February 22, 2023.
Giovanni Santos Purugganan, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner Giovanni S. Purugganan, an Examiner at the Land Registration Authority (LRA), was charged with Direct Bribery under Article 210 of the Revised Penal Code and violation of Section 3(b) of Republic Act No. 3019 . The charges stemmed from an incident on August 23, 2011, where he allegedly demanded and received P50,000.00 from private complainant Albert Avecilla in exchange for expediting the release of an LRA Order concerning the titling of property owned by Avecilla’s uncle, Benjamin Ramos. The Regional Trial Court (RTC) found Purugganan guilty of both charges. On appeal, the Sandiganbayan affirmed the conviction for Direct Bribery but acquitted him of the violation of RA 3019, Section 3(b), due to the prosecution’s failure to prove an indispensable element of the crime. Purugganan filed a Petition for Review on Certiorari before the Supreme Court.

ISSUE

The core issue is whether the Sandiganbayan correctly affirmed petitioner’s conviction for the crime of Direct Bribery.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Sandiganbayan’s Decision. The Court found that all elements of Direct Bribery were proven beyond reasonable doubt. The petitioner, a public officer, demanded and received P50,000.00 from the private complainant. The amount was received in consideration of an act (expediting the release of an LRA Order) which did not constitute a crime but was connected with the exercise of his official functions. The Court upheld the credibility of the prosecution witnesses and found the entrapment operation valid. The defense of denial and frame-up was deemed weak and unsupported by evidence. The penalty imposed by the Sandiganbayan was affirmed as within the range prescribed by law.