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  • CASE #12 Candelaria de Mesa Mangulabnan vs. People of The Philippines G.R No. 236848, June 08, 2020

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    Harlene Hemor
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    Mangulabnan, a court interpreter, was found guilty of direct bribery for acting as a middleman between a judge and a defendant in an election case. Mangulabnan admitted to receiving 20,000 pesos from the defendant and delivering it to the judge in exchange for a favorable decision. The Supreme Court upheld the guilty verdict, finding that Mangulabnan and the judge conspired to commit bribery based on the findings of the lower court and Mangulabnan's own admission. All conspirators are equally liable regardless of their level of participation in the crime.

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    Mangulabnan, a court interpreter, was found guilty of direct bribery for acting as a middleman between a judge and a defendant in an election case. Mangulabnan admitted to receiving 20,000 pesos from the defendant and delivering it to the judge in exchange for a favorable decision. The Supreme Court upheld the guilty verdict, finding that Mangulabnan and the judge conspired to commit bribery based on the findings of the lower court and Mangulabnan's own admission. All conspirators are equally liable regardless of their level of participation in the crime.

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    © All Rights Reserved
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    647 views2 pages

    CASE #12 Candelaria de Mesa Mangulabnan vs. People of The Philippines G.R No. 236848, June 08, 2020

    Uploaded by

    Harlene Hemor
    Mangulabnan, a court interpreter, was found guilty of direct bribery for acting as a middleman between a judge and a defendant in an election case. Mangulabnan admitted to receiving 20,000 pesos from the defendant and delivering it to the judge in exchange for a favorable decision. The Supreme Court upheld the guilty verdict, finding that Mangulabnan and the judge conspired to commit bribery based on the findings of the lower court and Mangulabnan's own admission. All conspirators are equally liable regardless of their level of participation in the crime.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as docx, pdf, or txt
    of 2

    CASE #12

    CANDELARIA DE MESA MANGULABNAN vs. PEOPLE OF THE PHILIPPINES


    G.R No. 236848, June 08, 2020

    FACTS:

    The Information alleged that on March 1998, accused Rodrigo R. Flores,


    Presiding Judge of the MTCC, Branch 2 City of San Fernando, Pampanga, together
    with Candelaria Mangulabnan, Court Interpreter and Chairman of Revision Committee
    of the same MTCC, demanded and requested the amount of P20,000 from Dario
    Manalastas. Manalastas was the defendant in an election protest case filed by Alberto
    Guinto before the sala of Judge Flores. Accused Mangulabnan received the amount as
    middleman in favor of Judge Flores, and in consideration of a decision in the case
    favorable to Manalastas.

    Sandiganbayan found Mangulabnan guilty of Direct Bribery, noting her admission


    in open court in a civil case for injunction filed by Manalastas, which formed part of the
    administrative case’s records, that she indeed received money from the latter and
    delivered it to Judge Flores.

    ISSUE:

    Whether petitioner Candelaria De Mesa Mangulabnan is guilty of the crime of


    Direct Bribery under Article 210 of the Revised Penal Code, as the co-conspirator of
    Judger Flores.

    HELD:

    YES. The conspiracy between the two accused has been duly proven by the
    findings of Judge Medina and by Mangulabnan’s own admission. When conspiracy is
    established, the responsibility of conspirators is collective, not individual, rendering all of
    them equally liable regardless of the extent of their respective participations.

    The Element constituting Direct Bribery have been sufficiently established


    considering that: (a) Mangulabnan and Judge Flores were indisputably public officers,
    being the Court Interpreter and Presiding Judge, respectively, of the MTCC of City of
    San Fernando, Pampanga, Branch 2 at the time of offense; (b) she acted as Judge
    Flores’ middleman in committing crime, specifically by receiving Twenty Thousand
    Pesos (P20,000.00) from Manalastas and delivering it to Judge Flores; (c) the amount
    was given in exchange for the rendition of a judgement in favorable to Manalastas, as
    may be inferred from Mangulabnan’s own admission that Judge Flores ordered the
    release of the decision only after receiving the P20,000.00 and (d) the rendition of
    judgment relates to the functions of Judge Flores.

    While SB’s findings appear to have been sourced from the documentary
    evidence submitted and admissions made in the related administrative and civil cases,
    the due execution of the documentary evidence has been stipulated upon by the
    parties, thus dispensing the presentation of further witnesses.

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