G.R. No. L-7015, August 19, 1912
THE UNITED STATES, plaintiff-appellee, vs. JOSE BENGSON, defendant-appellant.

FACTS

Jose Bengson, the justice of the peace of Urdaneta, Pangasinan, was charged with illegal exaction under Article 399 of the Penal Code. The complaint alleged that in October 1907, during a preliminary investigation concerning stolen carabaos belonging to Benigno Lucero and Esteban Larosa, Bengson demanded and received P6 from each owner to return their carabaos and avoid being sent to the Court of First Instance. The trial court convicted Bengson, sentencing him to imprisonment, restitution, and special temporary disqualification.

Bengson appealed, arguing that the evidence did not prove his guilt and that the judgment effectively convicted him of estafa, not illegal exaction. The defense presented evidence, including Exhibits A and B, showing that in October 1908nearly a year after the alleged crimeLucero and Larosa had filed a criminal complaint for estafa against Francisco Austria, Bengson’s former clerk, accusing Austria of exacting the same P6. The complainants denied filing this earlier complaint, but witnesses and documentary evidence corroborated its existence. Bengson claimed the charges were maliciously instigated by Austria after being dismissed.

ISSUE

Whether the evidence presented proves beyond reasonable doubt that Jose Bengson is guilty of the crime of illegal exaction.

RULING

No. The Supreme Court reversed the trial court’s decision and acquitted Jose Bengson. The Court found that the prosecution’s evidence was insufficient to establish guilt beyond reasonable doubt. Key to this conclusion was the defense’s presentation of Exhibits A and B, which demonstrated that the complaining witnesses had previously accused Francisco Austria of the same offense. This prior complaint, filed nearly a year after the alleged act, cast serious doubt on the credibility of the accusations against Bengson. The Court found the theory of the defensethat the charges were maliciously motivated by Austriato be plausible. Consequently, the Court dismissed the complaint and ordered Bengson’s release, with costs de oficio.