“xxx. On the contrary, in the later ruling in Merencillo v. People, 85 promulgated in 2007, the Court reiterated the restrictive interpretation given in Soriano, Jr. to the term transaction as used in Section 3(b) of Republic Act No. 3019 in connection with a differentiation between bribery under the Revised Penal Code and the violation of Section 3(b) of Republic Act No. 3019 by holding that the latter is "limited only to contracts or transactions involving monetary consideration where the public officer has the authority to intervene under the law."
- People vs. Sandiganbayan, et. al., GR 189063, Dec. 11. 2013.