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Zenaida V. Sazon, a Senior Forest Management Specialist, was convicted of Robbery Extortion after demanding bribes from a company to avoid confiscation of allegedly illegal logs. The Supreme Court upheld her conviction, confirming that all elements of robbery were present, including unlawful taking, intent to gain, and intimidation. The penalty was modified to reflect abuse of authority, resulting in an indeterminate sentence of 2 years and 10 months to 8 years and 21 days.

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40 views1 page

Case Digest

Zenaida V. Sazon, a Senior Forest Management Specialist, was convicted of Robbery Extortion after demanding bribes from a company to avoid confiscation of allegedly illegal logs. The Supreme Court upheld her conviction, confirming that all elements of robbery were present, including unlawful taking, intent to gain, and intimidation. The penalty was modified to reflect abuse of authority, resulting in an indeterminate sentence of 2 years and 10 months to 8 years and 21 days.

Uploaded by

nikolsheyn.09
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ZENAIDA V. SAZON V. SANDIGANBAYAN (G.R. No.

150873, FEBRUARY 10, 2009)


FACTS OF THE CASE:
Zenaida V. Sazon was a Senior Forest Management Specialist at the Department of Environment and
Natural Resources (DENR). On September 24, 1992, she was tasked with investigating illegal shipments
and resaw operations involving logs in Metro Manila. During the investigation, Sazon discovered logs at
R&R Shipyard that she believed were illegal, and demanded that the company submit documents to prove
the legality of their possession. However, the company was unable to provide the necessary documents,
which led Sazon to demand a bribe to "fix" the issue. Over the course of several meetings, Sazon initially
demanded ₱300,000.00, then ₱200,000.00, and finally ₱100,000.00, threatening the company
representatives with confiscation of the logs and prosecution if they failed to pay.
On October 14, 1992, an entrapment operation was set up, and Sazon was caught accepting
₱100,000.00 from a company lawyer, Atty. Teresita Agbi, in exchange for preventing the confiscation of the
logs. Sazon was arrested and charged with Robbery Extortion.
ISSUE:
Whether the Sandiganbayan erred in concluding that all the elements of robbery with intimidation
were present in this case.
Whether the Sandiganbayan erred in convicting Zenaida Sazon beyond a reasonable doubt for the
crime of robbery extortion.
RULING OF THE SUPREME COURT:
The Supreme Court affirmed the conviction of Zenaida Sazon for Robbery Extortion, with
a modification of the penalty imposed by the Sandiganbayan. The Court found that all the elements
of robbery were proven beyond reasonable doubt:
 Personal property (₱100,000) was unlawfully taken from R&R Shipyard.
 The taking was unlawful because Sazon demanded money in exchange for not carrying out
her official duties to confiscate the logs.
 There was intent to gain on Sazon’s part, as she demanded the bribe for personal benefit.
 Intimidation was present, as Sazon threatened the company representatives with the
confiscation of the logs and prosecution, thus creating fear and coercing them to comply.
 The Court rejected Sazon’s argument that no intimidation was involved, emphasizing that the
threat of prosecution and confiscation of property was sufficient to create fear in the minds of
the victims.
However, the penalty was modified to reflect the abuse of authority, even the Sandiganbayan failed
to appreciate the aggravating circumstance of "Abuse of Authority". The Court imposed an indeterminate
sentence of 2 years, 10 months, and 21 days of prision correccional as the minimum, and 8 years and 21
days of prision mayor as the maximum.

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