FACTS:

The case involved a petition for review on certiorari assailing the Decision and Resolution of the Sandiganbayan (SB) in a criminal case for violation of the Anti-Graft and Corrupt Practices Act. The petitioner, Raquil-Ali M. Lucman, was found guilty beyond reasonable doubt of violating Section 3 (c) of RA 3019. The case stemmed from an information charging Lucman of requesting and receiving a total of One Million Five Hundred Thousand Pesos (P1,500,000.00) from private complainants in exchange for his assistance in the investigation, processing, and approval of their applications for free patent titles for two parcels of land. Lucman denied the allegations and pleaded not guilty to the charges. However, the SB found him guilty of the crime charged and sentenced him to imprisonment for a period of six (6) years and one (1) month, with perpetual disqualification from holding public office. Lucman filed a motion for reconsideration, which was subsequently denied, leading to the filing of the present petition for review. The primary issue before the Court was whether or not the SB correctly convicted Lucman for the violation of Section 3 (c) of RA 3019. The Court ruled that the petition had no merit and affirmed Lucman's conviction. The Court found that all the elements of the crime had been established, including Lucman's position as a public officer, his authority to grant the applications for free patents, his demand and receipt of money from the private complainants, and the consideration for the grant of their applications. The Court also modified Lucman's sentence to imprisonment for an indeterminate period of six (6) years and one (1) month, as minimum, to nine (9) years, as the maximum, with perpetual disqualification from public office.

ISSUES:

1. Whether or not the Sandiganbayan correctly convicted Lucman for the crime of violation of Section 3 (c) of RA 3019.

RULING:

1. The Court affirmed the conviction of Lucman for violation of Section 3 (c) of RA 3019. The elements of the crime were proven beyond reasonable doubt: (1) Lucman was a public officer; (2) he secured or obtained, or would secure or obtain, for a person any government permit or license; (3) he directly or indirectly requested or received from said person any gift, present or other pecuniary or material benefit for himself or for another; and (4) he requested or received the gift, present or other pecuniary or material benefit in consideration for help given or to be given.

PRINCIPLES:

• Violation of Section 3 (c) of RA 3019 requires the offender to be a public officer, who requests or receives any gift, present, or other pecuniary or material benefit for himself or for another, in consideration of help given or to be given relating to the securing or obtaining of a government permit or license.

• The elements of the crime must be proven beyond reasonable doubt to secure a conviction.

• The court must assess the credibility of the witnesses and the surrounding facts and circumstances of the case to determine the guilt or innocence of the accused.