G.R. No. L-2971; April 20, 1951
FELICIANO MANIEGO y CATU, petitioner, vs. THE PEOPLE OF THEIPHILIPPINES, respondent.

FACTS

The petitioner, Feliciano Maniego, was convicted by the Court of Appeals for violating Article 210 of the Revised Penal Code (Direct Bribery). Although appointed as a laborer, he was placed in charge of issuing summons and subpoenas for traffic violations in the sala of Judge Crisanto Aragon of the Municipal Court of Manila. Furthermore, with the knowledge of the Clerk of Court and the Fiscal, he was permitted to write motions for dismissal of prescribed traffic cases against unrepresented offenders and submit them to the court. On February 27, 1947, complainant Felix Rabia inquired about a subpoena he received for a traffic violation. Maniego checked and informed Fiscal De la Merced that the case had prescribed. The Fiscal instructed Maniego that if the violator had no lawyer, he could write the motion for dismissal and have it signed by the party. According to Rabia and an NBI agent, Maniego informed Rabia he was subject to a P15 fine, and after Rabia said he had no money, Maniego offered to “fix” the case for P10. Rabia paid the P10, which Maniego pocketed. Maniego then prepared the motion for dismissal, had Rabia sign it, submitted it to the court, and it was granted. Maniego denied soliciting or receiving money.

ISSUE

Whether the petitioner, appointed as a laborer but temporarily performing functions such as preparing motions for dismissal of cases, qualifies as a “public officer” under Article 203 of the Revised Penal Code for the purpose of conviction under Article 210 (Direct Bribery).

RULING

Yes. The Supreme Court affirmed the conviction. The Court held that for the purpose of punishing bribery, the temporary performance of public functions is sufficient to constitute a person a public official under Article 203. The law’s definition of “public officer” is comprehensive and includes any person who performs public duties in the government as an employee or agent of any rank. Although Maniego was a laborer by appointment, he was temporarily designated to perform public functions—specifically, preparing motions for dismissal of cases. By accepting a monetary reward in consideration of performing this act (filing the dismissal motion), he committed all the essential elements of Direct Bribery: (1) he was a public officer (by virtue of temporarily performing public functions); (2) he received a gift or promise (P10); (3) the gift was given in consideration of his commission of an act not constituting a crime (filing the dismissal motion); and (4) the act related to his exercise of public functions. The Court cited precedent and reasoned that receiving a bribe is equally pernicious whether done by a temporary employee or a permanent official. The decision of the Court of Appeals was affirmed in toto.