Case: Marisfosque v.

People, 435 SCRA 332 (2004)

Facts:
Nazario Marifosque, a police sergeant, was charged with direct bribery under Article 210
of the Revised Penal Code of the Philippines. The charge stemmed from an incident
where he allegedly demanded and received money from Yu So Pong and his daughter,
Hian Hian Yu Sy, in exchange for the recovery of stolen Shellane gas tanks. Marifosque
argued that he was merely relaying a request for a reward from his police asset who
provided information leading to the recovery of the tanks. The Sandiganbayan convicted
Marifosque of direct bribery, finding that his actions and behavior demonstrated corrupt
intent to personally benefit from the situation.

Issue:
Did Marifosque’s acceptance of money, which he claimed was intended for his police
asset, constitute direct bribery as defined under Article 210 of the Revised Penal Code?

Ruling:
The Supreme Court upheld the Sandiganbayan’s conviction of Marifosque for direct
bribery.
The court found that:
Marifosque was a public officer, fulfilling the first element of direct bribery. He directly
received the bribe money, meeting the second element. The money was given in
exchange for the recovery of the stolen tanks, an act that, while not a crime itself, falls
under the scope of Article 210.
The act of receiving the money was directly connected to his duties as a police officer,
fulfilling the final element of direct bribery. The Court determined that the case fell under
the second paragraph of Article 210, which addresses situations where a public officer
accepts a gift in consideration for performing an act that, while not criminal, is related to
their official duties. Although the Sandiganbayan imposed the correct prison term, the
Court modified the fine, increasing it to three times the amount received by Marifosque,
as mandated by the law.
Case: Balderama v. People, 542 SCRA 423 (2008)

Facts:
Rolando L. Balderama and Rolando D. Nagal worked for the Land Transportation Office
(LTO) Field Enforcement Division. Juan S. Armamento, a taxi business owner, filed a
complaint with the Ombudsman against Balderama, Nagal, and two other LTO officers
(Lubrica and de Jesus). Armamento alleged the officers extorted “protection money”
from him to avoid apprehension and impounding of his taxi units for LTO violations. He
claimed to have paid them P300 twice a month from February to June 1992. When he
stopped payments, the LTO officers impounded one of his taxis, claiming a defective
meter, which was later proven false.
The Ombudsman filed nine Informations for direct bribery (Article 210 of the Revised
Penal Code) and one Information for violation of Section 3€ of R.A. No. 3019 (Anti-Graft
and Corrupt Practices Act) against the officers. The Sandiganbayan found Balderama,
Nagal, and Lubrica guilty of seven counts of direct bribery and the violation of R.A. No.
3019. They were sentenced to imprisonment, fines, and disqualification from public
office. The officers appealed the decision, arguing lack of conspiracy and presenting an
affidavit from Armamento recanting his earlier testimony. The Sandiganbayan denied
their appeals, upholding the convictions. Lubrica’s appeal to the Supreme Court was
denied due to its late filing.

Issue:
Did the Sandiganbayan err in finding the petitioners guilty of the offenses charged?

Ruling:
The Court upheld the Sandiganbayan’s finding that the elements of direct bribery were
present.
The petitioners were public officers who demanded and received money in exchange for
refraining from performing their official duties. The Court also upheld the conviction
under Section 3€ of R.A. No. 3019, finding that the petitioners caused undue injury to
Armamento through bad faith by falsely impounding his taxi. The Court dismissed the
petitioners’ alibi and denial as weak defenses.
The Court rejected Armamento’s recantation, citing its inherent unreliability and lack of
compelling circumstances to doubt his original testimony. The Court emphasized that
findings of fact by the Sandiganbayan are generally binding unless specific exceptions
are met, which were not present in this case.
Case: Estrada v. Sandiganbayan, 377 SCRA 538 (2002)

Facts:
In 2001, following the impeachment of President Joseph Ejercito Estrada, multiple
criminal complaints, including one for plunder under Republic Act No. 7080, were filed
against the former president, members of his family, and associates. Jose “Jinggoy”
Estrada, the then mayor of San Juan and the former president’s son, was named as
one of the respondents in the plunder case. Jinggoy Estrada filed a “Motion to Quash
or Suspend” the Amended Information, arguing that the Anti-Plunder Law was
unconstitutional. This motion, along with his subsequent motions for bail, were denied
by the Sandiganbayan. Jinggoy Estrada appealed these decisions.

Issues:
• Whether or not R.A. No. 7080 is unconstitutional.
• Whether or not the Plunder Law provides sufficient standards for courts to apply.
• Whether or not Jinggoy Estrada was denied due process because he was charged
with offenses and with alleged conspirators “with which and with whom he is not even
remotely connected.”
• Whether or not Jinggoy Estrada should be granted bail.

Ruling:
The Supreme Court upheld the constitutionality of R.A. No. 7080, citing its previous
ruling in Estrada v. Sandiganbayan.
The Court rejected Jinggoy Estrada’s argument that the Plunder Law lacks sufficient
standards. It explained that the penalty for plunder is clearly defined in Section 2 of R.A.
No. 7080. The Court also clarified that because Jinggoy Estrada is charged as a co-
conspirator, he is subject to the same penalties as former President Estrada.
The Court held that Jinggoy Estrada could only be held accountable for the specific
predicate acts he was alleged to have committed, as detailed in sub-paragraph (a) of
the Amended Information. This sub-paragraph alleged that Jinggoy Estrada conspired
with the former President to receive money from illegal gambling on several instances.
The Court found that the phrase “on several instances” demonstrates a series of
predicate acts, fulfilling the requirements for plunder under R.A. No. 7080.
The Court determined that, in the interest of clarity, Jinggoy Estrada should not be
penalized for conspiracies involving other co-accused, as described in sub-paragraphs
(b) to (d) of the Amended Information. However, the Court did not fault the Ombudsman
for including all the predicate acts in one Information. The Court reviewed the legislative
history of R.A. No. 7080 and explained that the law was intentionally structured to avoid
the complexity of filing multiple informations for complex financial crimes like plunder.
The Court clarified the concept of conspiracy under Philippine law. The Court
emphasized the difference between the Philippine and American legal systems’
approaches to conspiracy. In the Philippines, conspiracy is generally not a crime unless
specifically stated by law, and when alleged as a mode of committing a crime, does not
need to be described in extensive detail.
The Court addressed Jinggoy Estrada’s motion for bail. The Court remanded the matter
back to the Sandiganbayan for evidentiary hearings to determine whether the evidence
of Jinggoy Estrada’s guilt was strong enough to warrant continued denial of bail. The
Court noted that previous hearings had focused solely on medical evidence, and not on
the evidence regarding his guilt.
The petition was ultimately dismissed for failure to show that the Sandiganbayan acted
without or in excess of jurisdiction or with grave abuse of discretion.
Case: Wa-acon v. People, 510 SCRA 429 (2006)

Facts:

Robert P. Wa-acon was a Special Collecting Officer of the National Food Authority
(NFA) assigned to the Kadiwa Center at Moriones, Tondo, Manila. One of his duties was
to receive grains, including rice and mongo, and sell them to the public. Wa-acon was
responsible for collecting the proceeds from the sale of these grains. On September 28,
1981, a team of auditors from the Commission on Audit conducted an examination of
Wa-acon’s accountabilities. The audit team discovered a cash shortage of
P114,303.00. After deducting the cost of returned rice and empty sacks, the shortage
amounted to P92,199.20. Wa-acon denied misappropriating the funds, arguing that the
shortage may be attributed to discrepancies in the weight of the rice delivered to him.
He claimed that he received less rice than what was reflected in the receipts, but he
signed for the deliveries because he was told he would not be paid otherwise. He also
argued that the missing empty sacks were in the custody of the delivery man.

Issue:

Was Wa-acon’s guilt of malversation proven beyond a reasonable doubt?

Ruling:
The Supreme Court upheld the Sandiganbayan’s decision, finding Wa-acon guilty of
malversation. The Court explained that Article 217 of the Revised Penal Code, as
amended by Republic Act 1060, establishes a **rebuttable presumption that the failure
of a public officer to produce public funds upon demand constitutes *prima facie*
evidence that the funds were converted for personal use**. This presumption shifts the
burden of proof to the accused to present satisfactory evidence to rebut it.
The Court noted that Wa-acon failed to present sufficient evidence to overcome this
presumption. His explanations for the shortage were unsupported, and he did not
provide any corroborating evidence. He did not produce the delivery men who allegedly
had the missing empty sacks, nor did he offer any acknowledgment receipts. Further,
he did not present any witnesses to confirm his claims about discrepancies in rice
deliveries.
 The Court distinguished Wa-acon’s case from Madarang v. Sandiganbayan and Agullo
v. Sandiganbayan, where the accused were acquitted of malversation. In those cases,
the accused presented adequate evidence to demonstrate that the missing funds were
not converted for personal use. In contrast, Wa-acon relied solely on his own
uncorroborated testimony.
Therefore, the Court concluded that the prosecution had established a prima facie case
of malversation, and Wa-acon’s insufficient rebuttal meant that the presumption of guilt
remained.
Case: Quizo v. Sandiganbayan, 149 SCRA 108 (1987)

Facts:
Arturo Quizo, a Money Order Teller at the Cagayan de Oro Post Office, was found to
have a shortage of P17,421.74 in his accounts after an audit by the Commission on
Audit. The shortage included disallowed cash advances to co-employees,
accommodated private checks, and a small amount of actual cash shortage. Despite
Quizo fully reimbursing the missing funds, the Tanodbayan filed an information for
malversation of public funds against him with the Sandiganbayan. The Tanodbayan later
filed a motion to dismiss the case, arguing that full restitution was made and that Quizo
never personally benefitted from the missing funds. The Sandiganbayan denied both
the motion to dismiss and the subsequent motion for reconsideration, asserting that
damage to the government is not an essential element of malversation and that
restitution is not a defense.

Issue:

Did the Sandiganbayan err in denying the Tanodbayan’s motion to dismiss the
malversation case against Quizo?

Ruling:

Yes. The Supreme Court ruled that the Sandiganbayan gravely abused its discretion in
denying the motion to dismiss. The Court emphasized the prosecuting attorney’s
discretion in filing criminal charges, particularly when the prosecutor believes the
evidence is insufficient. The Tanodbayan, after a reinvestigation, found that Quizo had
not pocketed the money and recommended dismissal. The Court also found that Quizo
had successfully rebutted the prima facie presumption of guilt in malversation cases by
showing he hadn’t used the funds for personal gain.
The Court cited the Villacorta case, where an accused was acquitted of malversation
because the missing funds were not used for personal gain and the wrong payments
were made in good faith. Therefore, the Supreme Court granted the writ of certiorari, set
aside the Sandiganbayan’s resolutions, and dismissed the criminal case against Quizo.
Case: Magsuci v. Sandiganbayan, 240 SCRA 13 (1995)

Facts:
The case involves Hermenegildo M. Magsuci, the Regional Director of the Bureau of
Fisheries and Aquatic Resources (BFAR) for Region X. Magsuci was charged with the
complex crime of estafa through falsification of public documents. This stemmed from
his alleged involvement in a scheme where payments were released for construction
work that hadn’t been completed. The Sandiganbayan, the court handling the case,
found Magsuci guilty based on its finding of a conspiracy between him, a private
contractor (Jaime B. Ancla), and a BFAR engineer (David T. Enriquez). The
Sandiganbayan sentenced Magsuci to a prison term and fined him P5,000.

Issue:
Whether a head of office could be held criminally liable for relying on the actions of a
subordinate in the course of their official duties?

Ruling:

The Supreme Court reversed the Sandiganbayan’s decision, acquitting Magsuci. The
Court recognized that heads of offices must rely on their subordinates and their good
faith.
The Court emphasized that, while negligence may exist in such situations, conspiracy
requires a “conscious design to commit an offense.” The Court clarified that simply
noting, signing, and co-signing documents related to the actions of a subordinate, in the
regular performance of official duties, does not constitute sufficient evidence of
conspiracy.
The Court’s ruling reaffirmed the “Arias doctrine,” which shields heads of offices from
conspiracy convictions solely based on their reliance on subordinates, absent clear
evidence of their involvement in the illicit act.
Case: Campomanes v. People, 5115 SCRA 285 (2006)

Facts:

This case involves Florencio B. Campomanes, the then-President of the Federation

Internationale Des Echecs (FIDE), a private international organization, and his alleged
failure to render accounts for funds received from the Philippine Sports Commission
(PSC). The PSC, through its Chairman Cecilio G. Hechanova, had negotiated with FIDE
to host the 1992 Chess Olympiad and Congress in Manila. As part of its bid offer, the
PSC agreed to provide FIDE with significant financial support, including a one million
Swiss Francs guarantee deposited in the Philippine National Bank. The PSC ultimately
remitted a total of P 12,876,008.00 to FIDE between October 1990 and June 1992 for
the event. While FIDE, through Campomanes, acknowledged receiving these funds,
they did not provide an accounting liquidation detailing how the money was spent. A
subsequent audit by the Commission on Audit (COA) revealed the lack of both
acknowledgment receipts and accounting liquidation, leading to an investigation.
Despite demands from the COA for a refund or detailed accounting, Campomanes
failed to provide the necessary documentation.

Issue:

Whether Campomanes was guilty of failing to render accounts under Article 218, in
relation to Article 222, of the Revised Penal Code. This hinges on whether
Campomanes, as a private individual representing FIDE, was legally required to provide
an accounting to the COA.

Ruling:
The Supreme Court ruled in favor of Campomanes, overturning the Sandiganbayan’s
decision and acquitting him of the charges. The court found that the prosecution failed
to demonstrate that Campomanes was legally obligated to submit an accounting to the
COA. The court emphasized that penal statutes must be interpreted in favor of the
accused. While there may have been suspicion of financial irregularities, mere suspicion
is insufficient to warrant a criminal conviction. The court found that the COA’s authority
to demand an accounting from non-governmental entities like FIDE is contingent upon
either a specific law requiring it or a contractual obligation stipulated by the granting
institution (PSC in this case). Neither condition was met in this instance. The court
highlighted that the PSC and FIDE had entered into a contract for the Chess Olympiad
and Congress. FIDE, according to the court, fulfilled its obligations by successfully
organizing the events. The court determined that the laws presented by the Office of the
Special Prosecutor did not adequately prove a legal requirement for Campomanes to
submit an accounting to the COA. Notably, the court clarified that Section 102 of
Presidential Decree No. 1445 pertains to accountable officers within government
agencies and not to non-governmental entities receiving government funding.
Therefore, the Court acquitted Campomanes due to the prosecution’s inability to
establish all the elements of the crime, particularly the legal requirement for
Campomanes to render an accounting.
Case: Manlangit v. Sandiganbayan, 531 SCRA 420 (2007)

Facts:

Rosulo L. Manlangit, Officer-in-Charge for Information, Education, and Communication

of the Pinatubo Commission, received ₱176,300 for the Commission’s 6th Founding
Anniversary activities on October 16, 1998. He resigned a few months later without
accounting for the funds. The Commission’s Executive Director filed a complaint against
Manlangit for violating Articles 217 and 218 of the Revised Penal Code. Manlangit
claimed he had no intention of misappropriating the funds and blamed his failure to
submit a timely liquidation report on organizational changes, job searching, and
personal problems. He claimed to have submitted his report and settled the account on
July 12, 2000. However, the Commission’s Deputy Executive Director stated that
Manlangit had not submitted any report. The Office of the Deputy Ombudsman for
Luzon filed an information against Manlangit for violating Article 218. Despite a letter
from the Department of Budget and Management stating Manlangit had rendered an
accounting and requesting the case’s withdrawal, the Sandiganbayan convicted him.

Issue:
Whether a prior demand from the Commission on Audit (COA) is necessary for an
accountable officer to be convicted of violating Article 218 of the Revised Penal Code.

Ruling:
The Supreme Court denied Manlangit’s petition and affirmed the Sandiganbayan’s
decision, with a modification to the sentence. The Court held that prior demand is not an
element of the crime as defined in Article 218. The law only requires that a public officer
be mandated by law or regulation to render an account. The Court clarified that Article
218 differs from Act No. 1740, which was the subject of the Saberon case cited by
Manlangit, where prior demand was required. The Court highlighted that the COA
Circular No. 90-331 obligated Manlangit to submit a liquidation report within 20 days of
the year’s end. Since he failed to do so within the two-month period stipulated by Article
218, his subsequent submission in July 2000 was deemed too late. The Court modified
the penalty to an indeterminate prison term due to the lack of aggravating or mitigating
circumstances.
Case: Santos v. People, 563 SCRA 341 (2013)

Facts:
Judy Anne Santos (Santos) filed a petition with the Supreme Court to review a Court of
Tax Appeals (CTA) en banc resolution that denied her Motion for Extension of Time to
file a Petition for Review. The Petition for Review was intended to challenge the CTA
First Division’s denial of her Motion to Quash the information filed against her for tax
violations. The Bureau of Internal Revenue (BIR) investigated Santos for potential tax
violations for the taxable year 2002. Based on their findings, the BIR recommended
filing criminal charges against Santos for substantial underdeclaration of income, which
serves as prima facie evidence of a false or fraudulent return under the National Internal
Revenue Code (NIRC). The BIR estimated her tax liability from the underdeclaration to
be P 1,718,925.52, including penalties.
The Department of Justice (DOJ) conducted a preliminary Investigation and found
probable cause to file an Information against Santos. The first Information filed
contained discrepancies, and the State Prosecutor filed a second Information that
addressed those discrepancies.Santos filed a Motion to Quash the Information with the
CTA First Division, arguing that the Information did not constitute an offense, the filing
officer lacked authority, the CTA lacked jurisdiction, and the Information violated her due
process and equal protection rights. The CTA First Division denied the Motion to Quash,
leading Santos to file a Motion for Reconsideration, which was also denied.

Issue:
Whether a CTA Division’s resolution denying a motion to quash is a proper subject of an
appeal to the CTA en banc under Section 18 of Republic Act No. 1125, as amended by
Republic Act No. 9282.

Ruling:

The Supreme Court ruled that the CTA en banc correctly denied Santos’ Motion for
Extension of Time to File Petition for Review. The Court’s rationale for this ruling is as
follows:
• A petition for review under Section 18 of Republic Act No. 1125, as amended, functions
as an appeal, similar to those available in courts of general jurisdiction. While new to the
CTA, the process for filing a petition for review with the CTA en banc is comparable to
appeals in other Philippine courts and follows similar established procedures. Therefore,
the CTA should adhere to the Supreme Court’s established jurisprudence on petitions
for review and appeals.
• Generally, the denial of a motion to quash is an interlocutory order and not subject to
appeal or a petition for certiorari. A final order or judgment concludes a court’s
involvement in a case, whereas an interlocutory order leaves matters pending. Denying
a motion to quash means the case proceeds to trial, making it an interlocutory order.
Appealing interlocutory orders would cause unnecessary delays and expenses.
• While the general rule prohibits appeals of interlocutory orders, exceptions exist. In
exceptional cases, a special civil action for certiorari may be allowed to challenge an
interlocutory order if appealing would be inadequate. This applies when the tribunal
acted without jurisdiction, exhibited grave abuse of discretion, or when the order is
patently erroneous and an appeal would not provide adequate and expeditious relief.
• The CTA First Division did not commit grave abuse of discretion in denying Santos’
Motion to Quash. Certiorari is not meant to correct procedural errors or mistakes in
factual or legal findings but is used to address grave abuse of discretion or actions
exceeding a court’s jurisdiction. Santos’ grounds for the motion to quash did not
demonstrate such abuse of discretion.
Case: Abdulla v. People, 455 SCRA 78 (2005)

Facts:
Norma A. Abdulla was convicted by the Sandiganbayan of technical malversation,
defined and penalized under Article 220 of the Revised Penal Code. Abdulla was the
President of the Sulu State College. She was charged along with the college’s cashier,
Nenita Aguil, and Administrative Officer, Mahmud Darkis, for using funds allocated for
salary differentials of secondary school teachers to pay the terminal leave benefits of six
casual employees. Aguil and Darkis were acquitted, but Abdulla was found guilty and
initially sentenced to a fine of three thousand pesos and temporary special
disqualification for six years. The temporary special disqualification was later removed.
The prosecution presented documentary evidence showing that the Department of
Budget and Management (DBM) had approved the conversion of 34 secondary school
teacher positions to Instructor I items and allotted 40,000 pesos for salary differentials.
The evidence also showed that only six teachers were entitled to and paid salary
differentials, as 28 teachers already had equivalent salaries. The remaining 31,516.16
pesos from the 40,000 peso allotment was used to pay the terminal leave benefits of the
six casual employees. Abdulla appealed her conviction, arguing that the prosecution
failed to prove her criminal intent and that the elements of technical malversation were
not present.

Issue:
Did the prosecution prove the existence of criminal intent and all the essential elements
of technical malversation, as defined in Article 220 of the Revised Penal Code?

Ruling:
The Supreme Court granted Abdulla’s appeal and reversed the Sandiganbayan’s
decision, acquitting her of the crime charged. The Court found that the prosecution
failed to prove Abdulla’s criminal intent. Disbursing public funds for public use is not
inherently unlawful. In the absence of a presumption of unlawful intent, the burden of
proving criminal intent falls on the prosecution. The Court also found that the
prosecution failed to establish the third and fourth elements of technical malversation.
The funds used to pay the terminal leave benefits were sourced from a “lump sum
appropriation” and current savings, not a specific appropriation for salary differentials.
The authorization from the DBM was not considered an ordinance or law as required by
Article 220.
The Court emphasized that the absence of a law or ordinance specifically appropriating
the funds for salary differentials meant that Abdulla could not be held guilty of technical
malversation for using them for another public purpose.
Case: Barriaga v. Sandiganbayan, 457 SCRA 301 (2005)

Facts:

Dinah C. Barriga, the Municipal Accountant of Carmen, Cebu, was charged, along with
Virginio E. Villamor (the Municipal Mayor), with three offenses:
Malversation of Funds: In January 1996, Barriga and Villamor allegedly misappropriated
₱23,047.20 intended for the purchase of polyethylene pipes for a water system project.
Illegal Use of Public Funds (November 1995): Barriga and Villamor allegedly misused
₱1,305.00 from the Central Visayas Water and Sanitation Project Trust Fund for a
project in a barangay not designated as a recipient of the fund.
Illegal Use of Public Funds (January 1997): Barriga and Villamor allegedly misused
₱267,537.96 from the same trust fund, applying it to a project categorized under a
different level of the project than what the funds were appropriated for.
Barriga filed a Motion to Quash the Amended Informations arguing that the
Sandiganbayan lacked jurisdiction because:
Section 4 of Republic Act No. 8294 does not give the Sandiganbayan jurisdiction over
the crimes charged. The Amended Informations didn’t demonstrate a direct link between
the crimes and her duties as a Municipal Accountant. Municipal Accountants are not
accountable officers. Her position was classified as Salary Grade 24. The Informations
did not specify her role in the alleged conspiracy.

Issue:
Wether the Sandiganbayan had jurisdiction to try Barriga for malversation and illegal
use of public funds, despite her position as Municipal Accountant (Salary Grade 24) and
her argument that she was not an accountable officer.

Ruling:

The Supreme Court denied Barriga’s petition, upholding the Sandiganbayan’s

jurisdiction. The Court explained that while the Sandiganbayan generally needs specific
allegations linking the crime to the accused’s office, this is unnecessary when the office
itself is a fundamental part of the offense as defined by law. Malversation and illegal
use of public funds fall into this category, with the public office of the accused being an
essential element.

The Court emphasized the concept of conspiracy, citing past cases to establish that
even those not directly in control of public funds could be held accountable for
malversation or illegal use if they conspired with an accountable officer. Since Barriga
was accused of conspiring with the Municipal Mayor (Salary Grade 27), the
Sandiganbayan had jurisdiction, regardless of Barriga’s Salary Grade or her claim of not
being an accountable officer.

The Court clarified that while a Municipal Accountant might not typically be considered
an accountable officer under Section 474 of the Local Government Code, this didn’t
preclude a conviction for malversation if their duties involved handling public funds and
they misappropriated them. The key factor was the nature of the duties and the
individual’s responsibility for public money.
Case: People v. Galit, 135 SCRA 465 (1985)

Facts:
On August 23, 1977, Natividad Fernando was found dead in her home in Montalban,
Rizal. She had been stabbed multiple times, and the cause of death was determined to
be shock and hemorrhage. More than two weeks later, Galit was arrested by police and
turned over to the National Bureau of Investigation (NBI). While initially giving evasive
answers, Galit later confessed to the crime, implicating two others, Juling Dulay and
Pabling Dulay. Based on this confession, Galit was charged with Robbery with
Homicide. The prosecution presented a witness, Florentino Valentino, who claimed to
have overheard Galit confessing to his wife. Valentino alleged that Galit and his
accomplices planned the robbery and that Galit admitted to killing Fernando.
Galit denied any involvement in the crime, asserting that he was at home in Marikina,
Rizal, when the murder occurred. He also challenged the admissibility of his confession,
claiming it was obtained through torture, force, and intimidation by the NBI agents. He
stated he was denied access to a lawyer and that his family was unaware of his
detention for two weeks after his confession.

Issue:
Was the confession obtained from Galit admissible as evidence?

Ruling:
The Supreme Court found that Galit’s confession was inadmissible as evidence. The
Court determined that the confession was not voluntarily given and was obtained in
violation of Galit’s constitutional rights. The Court emphasized that the manner in which
the confession was obtained, involving torture and denial of legal counsel, was a clear
violation of Galit’s rights. The Court also found that the prosecution’s evidence, primarily
based on the testimony of Valentino, was insufficient to support a conviction.
The Supreme Court reversed the lower court’s decision, acquitted Galit of the charges,
and ordered his immediate release. The Court also directed that a copy of the decision
be sent to the Minister of Justice for potential action against the NBI officers involved in
the interrogation.