G.R. Nos. 56741-42. April 15, 1988 (Case Brief / Digest)

### Title:
**Aurora Mejia vs. Sandiganbayan and the People of the Philippines**

### Facts:

The cases stemmed from six separate ejectment cases filed by Eusebio Lu against different defendants, all decided against the defendants in the City Court of Manila. The defendants appealed to the Court of First Instance (CFI) of Manila, with the cases assigned to Branch XXVI presided over by Hon. Jose P. Alejandro. Five defendants entered a compromise agreement with Lu, but Josefina Meimban did not. Atty. Modesto R. Espano, representing Meimban, was informed of her decision to pursue her appeal separately.

Aurora Mejia, Branch Clerk of Court where Meimban’s case was pending, approached Meimban, suggesting assistance in exchange for PHP 1,000 intended as a “gift” for the judge. Despite initial hesitance, Meimban eventually gave PHP 1,000 to Mejia, incurring further demands from Mejia for more money supposedly to ensure favorable resolutions for the ejectment cases. Pilar Bautista and Gloria Antonio, related to other defendants, became involved through conversations with Meimban and eventually handed money to Mejia under the pretense of expediting their cases and influencing the judge’s decision.

The whole ordeal was brought to the attention of authorities, leading to Mejia’s prosecution in the Sandiganbayan under two criminal charges for violation of Section 3(b) of the Anti-Graft and Corrupt Practices Act (Republic Act No. 3019), alleging Mejia indirectly requested/received benefits in connection with transactions wherein she was supposed to intervene in her official capacity.

Mejia filed a petition for review on the Sandiganbayan’s decision convicting her, arguing issues related to jurisdiction, due process, the validity of the charges, and the credibility of evidence presented against her.

### Issues:

1. Whether the Sandiganbayan had jurisdiction over the case.
2. Whether the proceedings in Sandiganbayan violated the due process of law.
3. Whether Mejia could be convicted based on offenses not specifically alleged in the information.
4. Whether the discrepancies in the amounts stated in the information vs. those found by the Sandiganbayan invalidated the conviction.
5. Substantiality of evidence justifying the conviction.
6. Mejia’s claim that as Branch Clerk of Court, she didn’t intervene in case settings or formulate resolutions.
7. Whether the Sandiganbayan erred in allowing additional cross-examination on Mejia’s alleged attempt to bribe a prosecutor.

### Court’s Decision:

The Supreme Court upheld the Sandiganbayan’s conviction of Mejia, dismissing her petition for review. It agreed with the Sandiganbayan’s findings that Mejia, using her position as Branch Clerk of Court, exploited her relationship with the presiding judge to convince the complainants to give her money in exchange for favorable rulings. The court asserted that the discrepancies in the requested amounts and procedural issues raised by Mejia did not detract from the overall evidence of her guilt for violating the Anti-Graft and Corrupt Practices Act.

### Doctrine:

The Court reiterated important principles related to public service integrity, emphasizing that the administration of justice requires adherence to the highest standards of honesty and integrity. It pronounced that any form of corruption, especially within the judiciary, cannot be tolerated as it undermines the public’s trust in the legal system.

### Class Notes:

– Elements of the offense under Section 3(b) of the Anti-Graft and Corrupt Practices Act:
1. The offender is a public officer.
2. This officer requested or received a gift, present, etc.
3. It was for their personal benefit or another person’s.
4. This request/receipt was in connection with a government transaction where the officer is required to intervene by law.
– Jurisdiction of the Sandiganbayan under Presidential Decree No. 1606.
– The principle that findings of fact by the Sandiganbayan are conclusive unless there are missed facts or circumstances affecting the case’s outcome.
– Public integrity and rejection of any form of bribery within the judiciary are paramount for the fair administration of justice.

### Historical Background:

The case underlines the complexities of dealing with corruption within the judiciary, especially during a period of heightened emphasis on integrity and public service in the Philippines. It highlights the Sandiganbayan court’s role, established to adjudicate over criminal and civil cases involving public officials and employees, in line with the country’s efforts to combat corruption and maintain the integrity of public service.


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