ARANETA vs. CA (Digested Case Digest)

ARANETA v. CA [142 SCRA 532 (1986)]

Digested Case Digest

FACTS: Complainant Gertrudes Yoyongco approached the appellant, Atty. Araneta, to inquire about the procedure for filing a claim for death of her husband compensation.  She was told by the appellant that she had to pay PhP100 so that her claim would be acted upon. 

Yoyongco then went to her bro-in-law, Col. Yoyongco; the latter then gave her 2 PhP50 bills and instructed her to go to Col Laureaga.  The latter concocted a plan to entrap the appellant.  The 2 PhP50 bills were marked w/ notations “CC-NE-1” and “CC-NE-2”, photographed and dusted w/ ultra-violet powder.

She again approached Araneta the officer to process her claim but was again asked if she already had P100.  Yoyongco brought out the 2 P50 bills & handed them to the appellant.  As she took hold of the money, officer Balcos grabbed her hand & arrested her.  In the PC headquarters, Atty Araneta’s hands were examined for the presence of UV powder & result was positive.

Issue: Was the accused caught through entrapment?

Held: YES.

RATIO: There is entrapment when law officers employ ruses and schemes to ensure the apprehension of the criminal while in the actual commission of the crime.  Wherefore, appellant is guilty of the crime of bribery, a violation of Sec 3 RA No 3019 known as the “Anti-Graft and Corrupt Practices Act.”