Sandiganbayan Upholds Conviction of Former BIR Official
The Sandiganbayan has confirmed the conviction of a former Bureau of Internal Revenue (BIR) official involved in a fraudulent land title transaction. The case centers on a demand for P125,000 in exchange for the transfer of a land title in 2005.
Veronica Santiago Carpio, who once led the Taxpayers Service Division of Revenue District Office No. 38 at the BIR, was found guilty of estafa by the Quezon City Regional Trial Court (RTC). She received a one-year prison sentence and was ordered to pay P125,000 in damages to the complainant, Evangeline S. Magleo.
Details of the Case and Court Ruling
Although Carpio’s prison sentence stands, the anti-graft court adjusted the payment terms for damages. The court ruled that the P125,000 should accrue legal interest at 12 percent annually from the date the case was filed on December 29, 2011, until June 30, 2013. From July 1, 2013, until the decision becomes final and fully satisfied, the interest rate is six percent per year.
Prosecutors presented evidence that Carpio falsely claimed to have influence with the Registry of Deeds in Quezon City. She convinced the late Ofelia Salas and complainant Magleo that she could facilitate transferring ownership of a property and issue a new Transfer Certificate of Title (TCT) under Magleo’s name. This arrangement required a payment of P125,000.
However, the title transfer never took place, and the money was not refunded to Magleo.
Appeal and Court’s Rejection
Carpio appealed the RTC’s decision, asserting that the P125,000 was actually used to cover the land title transfer costs. She also argued that the amount was insufficient to cover the necessary taxes for registering the land sale and securing the title in Magleo’s name.
Despite her denial, the anti-graft court pointed out that Carpio’s signature appeared on the receipt acknowledging the payment. The court emphasized that denial alone is a weak defense without strong evidence to prove innocence.
“Unless supported by clear and convincing evidence, denial cannot prevail over the positive declaration of a victim who, like in this case, in a natural and straightforward manner, convincingly testified on the circumstances surrounding the fraudulent representation made by appellant,” the decision stated.
The court further noted that Carpio’s inconsistent statements failed to outweigh Magleo’s credible testimony. Consequently, the conviction was upheld.
Final Decision and Legal Implications
The 22-page ruling was authored by Associate Justice J. Ermin Ernest Louie R. Miguel, with concurrence from the Fourth Division Chairperson and Associate Justices Michael Frederick L. Musngi and Lorifel L. Pahimna.
This case highlights the consequences public officials face when abusing their positions for personal gain, especially in transactions involving land titles.
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