GR L 75160; (March, 1988) (Digest)
G.R. No. L-75160 March 18, 1988
LEONOR FORMILLEZA, petitioner, vs. THE HONORABLE SANDIGANBAYAN, First Division and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Leonor Formilleza, a personnel supervisor at the NIA, was charged with indirect bribery before the Sandiganbayan. The charge stemmed from an entrapment operation on February 29, 1984, initiated by complainant Estrella Mutia, whose project-based appointment had expired. Mutia alleged that Formilleza demanded money to facilitate her renewed appointment. Mutia reported this to PC authorities, who orchestrated an entrapment using marked money dusted with fluorescent powder. During a meeting at the NIA canteen, Mutia claimed she handed the money to Formilleza under the table, at which point PC operatives apprehended Formilleza. Photographs were taken, and Formilleza tested positive for the powder. The Sandiganbayan convicted Formilleza, finding the prosecution’s version credible.
ISSUE
Whether the Sandiganbayan erred in convicting petitioner Leonor Formilleza of indirect bribery, as her guilt was not proven beyond reasonable doubt.
RULING
Yes. The Supreme Court reversed the Sandiganbayan’s decision and acquitted Formilleza. The Court meticulously reviewed the evidence and found the prosecution’s case fraught with reasonable doubt. Critical circumstances were overlooked by the Sandiganbayan. First, the entrapment was arranged by PC colleagues of Mutia’s husband, introducing a potential motive for fabrication. Second, the key prosecution witness, PC Sgt. Abanes, admitted he did not actually witness the passing of money, as his view was obstructed, and his photographs only captured events after the alleged exchange. Third, an impartial witness, Mrs. Sevilla, testified she saw no money change hands and described Formilleza’s reaction upon arrest as one of shocked innocence, shouting at Mutia, “What are you trying to do to me?” This reaction was inconsistent with guilt. The Court emphasized that moral certainty is required for conviction, and the evidence failed to meet this standard. The confluence of the questionable entrapment origins, the lack of direct eyewitness testimony to the crime’s core act, and the accused’s credible demeanor created reasonable doubt as to her guilt. Consequently, the petition was granted, and Formilleza was acquitted.