G.R. Nos. L-56741-42 April 15, 1988
AURORA MEJIA, petitioner, vs. HON. MANUEL PAMARAN, HON. ROMEO ESCAREAL, HON. CONRADO MOLINA, Presiding Justice and Associate Justices of the First Division SANDIGANBAYAN, and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Aurora Mejia, a Branch Clerk of Court of the Court of First Instance of Manila, was convicted by the Sandiganbayan for two counts of violating Section 3(b) of Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act). The charges stemmed from separate incidents where she allegedly requested and received money from two litigants, Josefina Meimban and Pilar Bautista, in connection with pending court cases. In Criminal Case No. 1988, Mejia was accused of receiving P1,000 from Meimban for the early setting and favorable resolution of a motion to withdraw a compromise agreement in an ejectment case. In Criminal Case No. 1989, she was accused of receiving P500 from Bautista to facilitate the issuance of a writ of execution in another case.
The prosecution evidence, primarily based on the testimonies of the complainants, established that Mejia, exploiting her official position, solicited and received the amounts under the pretext of influencing court proceedings. The defense denied the accusations, challenging the credibility of the witnesses and the jurisdiction of the Sandiganbayan.

ISSUE

The primary issues raised by the petitioner were: (1) whether the Sandiganbayan had jurisdiction over the case and was constitutionally constituted; (2) whether the informations were fatally defective for alleging amounts different from those found by the court; and (3) whether the evidence was sufficient to support a conviction.

RULING

The Supreme Court denied the petition and affirmed the Sandiganbayan’s decision. On jurisdiction, the Court held that the Sandiganbayan was validly created and constitutionally mandated to try public officers for graft and corruption. The procedural rules governing appeals from its decisions do not violate the constitutional guarantees of due process and equal protection, as they are reasonable classifications based on substantive distinctions.
Regarding the alleged discrepancies in the amounts stated in the informations and those found by the court, the Court ruled they were not fatal. The variance between P1,000 and P500 in the respective cases did not prejudice the petitioner’s substantial rights, as the core accusation—the corrupt request and receipt of money in relation to her office—remained proven. The essence of the offense under Section 3(b) of R.A. 3019 is the act of requesting or receiving any gift or present in connection with one’s official functions, not the precise amount.
On the sufficiency of evidence, the Court found the testimonies of the complainants credible, consistent, and sufficient to establish guilt beyond reasonable doubt. Their positive identification of Mejia and detailed accounts of the transactions prevailed over her general denials. The Court emphasized that personnel involved in the administration of justice must adhere to the highest standards of integrity, and any corrupt practice within the judiciary warrants severe condemnation to preserve public trust in the judicial system.