TITLE SIX- CRIMES AGAINST PUBLIC MORALS

CHAPTER 1- Gambling and Betting.

Presidential Decree No. 1602 (as amended)
This law, which repealed and modified earlier articles in the Revised Penal Code, is the main law that
penalizes illegal gambling in the Philippines.
• Illegal Gambling: This includes any game of chance, like card games, mahjong, and dominoes,
where a person wagers money or anything of value.
• Betting on Sports Contests: It is illegal to bet on the results of any sports contest unless it is
authorized by law.
• Illegal Horse Racing: The law prohibits illegal betting on horse races, such as those that are not
officially sanctioned by the Philippine Racing Commission.
• Illegal Cockfighting: The law prohibits illegal cockfighting, which includes any cockfight that is not
officially sanctioned by the government. . The law specifies that cockfighting is only legal in
licensed cockpits on Sundays and legal holidays.

Elements of Illegal Gambling

The elements of illegal gambling are:
1. A game of chance is being played.
2. The game is played with money or other things of value.
3. The game is not authorized by law.
Penalties and Liabilities
The penalties for illegal gambling vary depending on a person's involvement in the crime.
• Players: A person who is merely a player in an illegal game of chance.
• Maintainers, Bankers, and Personnel: A person who is a maintainer or a banker of the illegal game
of chance. They face a more severe penalty.
• Betting on Sports Contests: A person who bets on a sports contest that is not authorized by law.
• Illegal Horse Racing: A person who illegally bets on a horse race.
• Illegal Cockfighting: A person who is involved in illegal cockfighting.

P.D. 483 (Illegal Gambling)

This law penalizes a person who maintains or operates an illegal gambling house or establishment.
The law considers a gambling house to be an establishment where illegal gambling is being played.

P.D. 449 (Cockfighting Law of 1974)

This law specifically regulates the sport of cockfighting. It specifies that cockfighting is only legal in
licensed cockpits on Sundays and legal holidays. Any cockfight that is not sanctioned by this law is
considered illegal.

Chapter 2: Offenses Against Decency and Good Customs

Decency and Customs
• Decency refers to standards of proper behavior, modesty, and good taste in a community. It's
about what is considered socially acceptable and respectful.
• Customs are long-established social conventions, practices, and traditions that are considered
binding rules of conduct within a community.
Article 200: Grave Scandal
This crime involves acts that are highly offensive to public morals and decency.
• Elements of Grave Scandal:
1. The offender performs an act.
2. The act is highly scandalous as it offends decency or good customs.
3. The act is committed in a public place or within public knowledge or view.
4. The act does not fall under any other specific crime in the Revised Penal Code.
• Grave Scandal vs. Alarms and Scandals:
o Grave Scandal involves acts that are offensive to morality and decency (e.g., public
indecency).
o Alarms and Scandals (Article 155) involves acts that cause public disturbance or alarm
(e.g., discharging a firearm in public).

Article 201: Immoral Doctrines, Obscene Publications and Exhibitions, and Indecent Shows
This article penalizes the promotion of immorality and obscenity.
• Persons Liable:
o Any person who sells, distributes, or exhibits obscene publications, books, or shows.
o Any person who performs indecent or immoral shows.
o Any person who promotes or publishes obscene or immoral doctrines.
• Test of Obscenity: The legal test to determine if something is obscene is a three-pronged standard,
which asks if the material:
1. Appeals to the prurient interest (an excessive or unwholesome interest in sexual matters).
2. Depicts sexual conduct in a patently offensive way.
3. Lacks serious literary, artistic, political, or scientific value.
o For a material to be considered obscene, all three conditions must be met.

Article 202: Vagrants and Prostitutes - Penalty

This article addresses vagrancy and prostitution, though the law on vagrancy has been amended.
• R.A. 10158: Decriminalizing Vagrancy: Republic Act No. 10158 decriminalized vagrancy. This
means that a person can no longer be arrested and punished for simply being a vagrant.
• Who are vagrants? Before the law was decriminalized, vagrants were defined as persons with no
visible means of subsistence who neglected to apply themselves to a lawful calling.
• Who are prostitutes? Prostitutes are women who, for money or profit, habitually indulge in
sexual intercourse or lascivious conduct. The law specifically refers to women, which is a point
of contention and is viewed by some as discriminatory.
• Is sexual intercourse a necessary element? No, sexual intercourse is not a necessary element
to constitute prostitution. The law also includes lascivious conduct as a punishable act, which
means that any act that is a form of sexual exploitation in exchange for money can be considered
prostitution.
• Is there a crime of prostitution by conspiracy? No, there is no specific crime of "prostitution by
conspiracy." However, a person who conspires with others to commit prostitution may be held
liable for other crimes like human trafficking under R.A. 9208 (the Anti-Trafficking in Persons Act of
2003) or for white slave trade under the Revised Penal Code, which penalize those who profit from
prostitution.
TITLE SEVEN- CRIMES COMMITTED BY PUBLIC OFFICERS
CHAPTER 1 - Preliminary Provisions: Public Officers
A person is considered a public officer if they hold a public office and are vested with the authority to
perform a public function. They take an oath of office, which they are bound to uphold.
The three forms of breach of oath or duty are:
• Malfeasance: Performing an act that is illegal or a crime.
• Misfeasance: Performing a legal act in an illegal or improper way.
• Nonfeasance: Failing to perform an act that is required by law.

Malfeasance and Misfeasance in Office

• Malfeasance: Committing an act that is inherently illegal (e.g., a judge issuing a judgment they
know is wrong).
• Misfeasance: Improperly performing a legal act (e.g., a police officer using excessive force during
an arrest).
• Nonfeasance: Failing to perform a duty required by law (e.g., a prosecutor not filing a case).
• Sources of Unjust Judgment: An unjust judgment can come from two sources:
1. Knowing an act is unjust.
2. Being negligent in a way that leads to an unjust act.

Dereliction of Duty
Article 204: Knowingly Rendering Unjust Judgment
This crime is committed by a judge who issues a judgment that they know is unjust.
• Elements: The offender is a judge, and they issue a judgment that they know to be unjust.
• Unjust Judgment: A judgment that is contrary to the law or a clear injustice.
Article 205: Judgment Rendered Through Negligence
This crime is committed by a judge who issues an unjust judgment due to a lack of due care.
• Elements: The offender is a judge, and they issue a judgment that is unjust due to their
negligence.
• "Manifestly unjust": A judgment that is so clearly wrong that a person of ordinary intelligence
would recognize it as unjust.
Article 206: Unjust Interlocutory Order
This crime is committed by a judge who issues an unjust order while a case is still pending.
• Elements: The offender is a judge, and they issue an interlocutory order that is unjust.
• Interlocutory Order: An order issued by a judge while a case is still pending. It does not decide the
final outcome of the case.
Article 207: Malicious Delay in the Administration of Justice
This crime is committed by a judge who intentionally delays a case.
• Elements: The offender is a judge, and they maliciously delay a case.
Article 208: Prosecution of Offenses; Negligence and Tolerance
This crime is committed by a public officer who fails to perform their duty to prosecute a crime.
• Punishable acts:
1. Negligence: A public officer negligently refrains from filing a criminal case.
2. Tolerance: A public officer tolerates the commission of a crime.
 • Elements: The offender is a public officer who has the duty to prosecute a crime, and they
maliciously and negligently fail to do so.
• Offenders: Any public officer with the duty to prosecute, such as a prosecutor or a police officer.
• "Maliciously": With the intent to cause harm or with the intent to defy the law.
• Police officer: Yes, a police officer who tolerates a crime or fails to apprehend an offender can be
held liable for dereliction of duty.
• Barangay Chairman: Yes, a Barangay Chairman can be held liable for dereliction of duty if they fail
to perform their duty to maintain peace and order.
• Prevaricacion: The crime committed by a public officer who betrays their trust. It covers all forms
of dereliction of duty, including negligence and tolerance.
• Prevaricacion vs. Dereliction of Duty: Prevaricacion is the act of dereliction of duty, while
dereliction of duty is the failure to perform a duty.
Article 209: Betrayal of Trust by an Attorney
This crime is committed by an attorney who betrays a client's trust.
• Punishable acts:
1. Revealing a client's secrets.
2. Representing conflicting interests.
3. Refusing to return a client's property.
• Prospective clients: Communications made to prospective clients are also considered
confidential.

Bribery
Bribery is the crime of giving or receiving money or anything of value in exchange for an illegal act.
• Kinds of Bribery:
1. Direct Bribery: A public official receives something of value in exchange for performing an
illegal act.
2. Indirect Bribery: A public official receives something of value in exchange for a legal act.
Article 210: Direct Bribery
• Elements:
1. The offender is a public officer.
2. The offender receives money or other thing of value.
3. The public officer agrees to perform an illegal act in exchange for the payment.
• Public official accepting consideration and turning it over: If the public official accepts the
consideration and turns it over to his superior, there is no crime committed, as there is no intent to
defraud the government.
• Frustrated Bribery: No, there is no frustrated bribery. The crime of bribery is consummated once
the agreement is made.
Article 211: Indirect Bribery
• Elements:
1. The offender is a public officer.
2. The offender receives a gift or a promise from a person.
3. The gift or promise is given in consideration of an official act, but not in exchange for a
specific illegal act.
• Distinctions:
o Direct Bribery: The act is illegal, and the payment is for a specific illegal act.
 o Indirect Bribery: The act is legal, and the payment is a gift or a token of appreciation.
Article 211-A: Qualified Bribery
• Elements:
1. The offender is a public officer.
2. The offender is in a position of power or authority.
3. The offender receives money or other thing of value from a person who is in need of a
service from the government.
Article 212: Corruption of Public Officials
This crime is committed by a private person who bribes a public official.
• Elements: The offender is a private person who offers or gives a gift to a public officer.
• Public officer refuses to be corrupted: The crime is corruption of a public official, and the public
officer is not liable for any crime.

CHAPTER 3- Frauds and Illegal Exactions and transactions.

Article 213: Frauds Against the Public Treasury and Similar Offenses
This article covers two distinct crimes: fraud against the public treasury and illegal exactions.
Punishable Acts
• Fraud against the public treasury: This occurs when a public officer enters into an agreement or
uses a scheme to defraud the government in a transaction involving public funds or property, such
as furnishing supplies or making contracts.
• Illegal exactions: This involves a public officer who is in charge of collecting taxes, fees, or other
payments and commits any of the following acts:
1. Demanding payment that is different from or larger than what the law allows.
2. Failing to issue an official receipt for money collected.
3. Collecting payment in a form that is different from what the law provides (e.g., accepting
goods instead of cash).
Elements of Fraud Against Public Treasury
1. The offender is a public officer.
2. The public officer is dealing with a person regarding public funds or property.
3. The public officer enters into an agreement or uses a scheme to defraud the government.
Elements of Illegal Exactions
1. The offender is a public officer entrusted with the collection of taxes, fees, or other imposts.
2. The public officer commits any of the acts of illegal exaction enumerated in Article 213.
Who May Be Liable for Illegal Exaction?
Only a public officer who is directly involved in the collection of public funds can be held liable for illegal
exaction.

Article 214: Other Frauds

This article deals with a public officer who commits fraud while taking advantage of their official position.
• Elements:
1. The offender is a public officer.
2. They take advantage of their official position.
 3. They commit any of the frauds or deceits found in the Revised Penal Code, such as estafa
or swindling.

Article 215: Prohibited Transactions

This crime is committed by an appointive public officer who becomes involved in certain financial
transactions within their jurisdiction.
• Elements:
1. The offender is an appointive public officer.
2. During their incumbency, they become directly or indirectly interested in a transaction of
exchange or speculation.
3. The transaction is within the territory subject to their jurisdiction.

Article 216: Possession of Prohibited Interest by a Public Officer

This article prohibits a public officer from having a financial interest in a contract or business that they are
officially required to be involved in.
• Persons Liable:
o Any public officer who becomes directly or indirectly interested in a contract or business in
which it is their official duty to intervene.
o The law also extends to experts, arbitrators, private accountants, guardians, and
executors who take part in a transaction or contract connected to an estate or property they
are involved in.

CHAPTER 4- Malversation of Public Funds or Property.

What are the punishable acts?
Malversation is the crime of misappropriating public funds or property by a public official. The punishable
acts are:
1. Misappropriating, taking, or converting public funds or property for personal use.
2. Allowing another person to take public funds or property.
3. Using public funds or property for purposes other than what is intended by law.
4. Failing to account for public funds or property.

Who are "accountable officers"?

An accountable officer is a public official who, by reason of their office, is directly in charge of or
responsible for public funds or property. This can include a treasurer, a cashier, or any other public official
who has custody of public money.
Is it necessary that the offender actually misappropriated the funds?
Yes, it is necessary. The offender must have misappropriated, taken, or converted the funds. The crime
is not committed by mere negligence.
Is it necessary that the offender profited by his malversation?
No, it is not necessary that the offender profited from the malversation. The crime is committed once the
offender misappropriates the funds, regardless of whether they profited from it.
Is there a crime of malversation through negligence?
Yes, there is a crime of malversation through negligence. It occurs when a public officer, through their
negligence, allows another person to take or misappropriate public funds or property.
Is damage to the government necessary?
No, damage to the government is not necessary to constitute malversation. The crime is committed
once the offender misappropriates public funds.
What if the money is refunded on the same day?
If the money is refunded on the same day, malversation is still committed. The refund does not erase the
crime, as the crime is complete once the funds are misappropriated. The refund may be considered a
mitigating circumstance in court.
Can a private person commit the crime of malversation?
No, a private person cannot commit the crime of malversation. The crime is a public offense that can
only be committed by a public officer. However, a private person can be held liable as an accomplice or a
co-principal if they conspired with a public officer to commit the crime.
If falsification of documents was resorted to for the purpose of concealing malversation, is a
complex crime committed?
Yes, a complex crime is committed. The falsification of documents is a means to commit the crime of
malversation, and the two crimes are considered a single offense for which a single penalty is imposed.

Article 218: Failure of Accountable Officer to Render Accounts

This crime is about a public officer who fails to render an accounting of public funds.
• Elements: The offender is an accountable officer, and they fail to render an account of public
funds when required to do so by law.

Article 219: Failure to Render Accounts Before Leaving the Country

This crime is committed by a public officer who fails to render an accounting before leaving the country.
• Elements: The offender is a public officer who is an accountable officer, and they fail to render
an account of public funds before leaving the country.

Article 220: Illegal Use of Public Funds or Property

This crime, also known as technical malversation, is committed when a public officer uses public funds
for a purpose other than what is intended by law.
• Elements: The offender is a public officer, and they use public funds or property for a purpose
that is different from what is intended by law.
• Why "technical malversation"? It's called "technical malversation" because the offender does not
personally profit from the crime. The funds are used for a public purpose, but a different public
purpose than what the law allows.
• How is it committed? It is committed when a public officer diverts public funds from their
intended purpose.
• Distinctions:
o Malversation: The offender misappropriates public funds for their personal use.
o Technical Malversation: The offender uses public funds for a different public purpose.

Article 221: Failure to Make Delivery of Public Funds or Property

This crime is committed by a public officer who fails to deliver public funds or property to a person who is
legally entitled to receive it.
• Elements: The offender is a public officer who has the duty to deliver public funds or property, and
they fail to deliver the funds or property when legally required to do so.
Article 222: Officers Included in the Preceding Provisions
The public officers who are liable under the preceding provisions are those who are directly in charge of
public funds or property, as well as those who are responsible for the custody of public money. This
includes a treasurer, a cashier, and any other public officer who has custody of public funds or property.

CHAPTER 5- Infidelity of Public Officers.

Section 1: Infidelity in the Custody of Prisoners
This section covers crimes related to the escape of prisoners.
Article 223: Conniving with or Consenting to Evasion
A public officer who has a prisoner in their custody consents to or connives with the prisoner's escape.
Article 224: Evasion Through Negligence
• Elements:
1. The offender is a public officer who has a prisoner in their custody.
2. The prisoner escapes due to the public officer's negligence.
Article 225: Escape of Prisoner under the Custody of a Private Person
• Elements:
1. A person is a prisoner who is not a public officer.
2. The person has a prisoner in their custody or charge by virtue of a court order or a warrant.
3. The prisoner escapes due to the private person's negligence.

Section 2: Infidelity in the Custody of Documents

This section covers crimes related to the handling of official documents.
Article 226: Removal, Concealment, or Destruction of Documents
• Elements:
1. The offender is a public officer.
2. The offender is entrusted with official documents or papers.
3. The offender removes, conceals, or destroys the documents.
4. The act causes serious damage to the public or a third party.
• How the crime is committed: This crime can be committed by removing a document from its
official place, concealing it to prevent others from seeing it, or destroying it to prevent its use.
Article 227: Officer Breaking Seal
• Elements:
1. The offender is a public officer.
2. The offender is in custody of papers or property sealed by proper authority.
3. The offender breaks the seals or permits them to be broken.
• Is damage or intent to cause damage necessary? No, neither damage nor the intent to cause
damage is necessary. The crime is committed once the seal is broken. The law punishes the breach
of trust in the custody of the document.
Article 228: Opening of Closed Documents
• Elements:
1. The offender is a public officer who is not covered by Article 227.
2. The offender opens a closed document or paper entrusted to their custody.
 3. The offender opens the document without proper authority.

Section 3: Revelation of Secrets

This section covers crimes related to the improper disclosure of secrets.
Article 229: Revelation of Secrets by an Officer
• Punishable Acts:
1. A public officer reveals any secret known to them by reason of their official capacity.
2. A public officer wrongfully delivers papers that should not be published.
• Are military secrets or those affecting national security covered? No, this article does not
cover military secrets or those affecting national security. Those crimes are covered by other
laws, such as the Articles of War.
• Difference between Revelation of Secrets and Infidelity in the Custody of Documents:
o Revelation of Secrets: The crime is about the disclosure of the contents of a document.
o Infidelity in the Custody of Documents: The crime is about the physical act of removing,
concealing, or destroying the document itself.
Article 230: Public Officer Revealing Secrets of a Private Individual
• Elements:
1. The offender is a public officer.
2. They learn the secrets of a private individual due to their office.
3. They reveal the secrets.
• Should the secrets be revealed publicly? No, the secrets do not need to be revealed publicly. The
crime is committed once the secret is revealed to anyone, even a single person, without proper
authority.

CHAPTER 6- Other Offenses or Irregularities by Public Officers.

Section 1: Disobedience, Refusal of Assistance, and Maltreatment of Prisoners
Article 231: Open Disobedience
• Elements: The offender is a judicial or executive officer who openly refuses to execute a lawful
judgment, decision, or order from a superior authority.
Article 232: Disobedience to Order of a Superior Officer
• Elements:
1. The offender is a public officer.
2. They have suspended the execution of their superior's orders.
3. They disobey their superior after the suspension has been disapproved.
Article 233: Refusal of Assistance
• Elements:
1. The offender is a public officer.
2. A competent authority demands their cooperation.
3. They fail to lend their cooperation toward the administration of justice or other public
service.
Article 234: Refusal to Discharge Elective Office
• Elements:
 1. The offender is a person who was elected by popular vote to a public office.
2. They refuse, without a legal motive, to be sworn in or to discharge the duties of the office.
Article 235: Maltreatment of Prisoners
• Elements:
1. The offender is a public officer who has the actual charge of prisoners.
2. The offender maltreats the prisoner.
• When a person is maltreated by a public officer who has actual charge of prisoners, how many
crimes may be committed? Only one crime, maltreatment of prisoners.
• If the public officer who maltreated the prisoner is not charged with the custody of the
prisoner, what crime is he responsible for? The public officer would be responsible for the crime
of physical injuries or grave coercion, depending on the severity of the act.
• To what does maltreatment refer? Maltreatment refers to any physical or psychological harm
inflicted on a prisoner that is not a part of a lawful sanction.
• What if the person maltreated is not a convict or a detention prisoner? If the person maltreated
is not a prisoner, the crime committed is not maltreatment of prisoners. The public officer would
be liable for physical injuries or torture, depending on the circumstances, and may also be liable
under the Anti-Torture Act (RA 9745).

Section 2: Anticipation, Prolongation, and Abandonment of the Duties and Powers of Public Office
Article 236: Anticipation of Duties of a Public Office
• Elements:
1. The offender assumes the duties of a public office.
2. They do so without being sworn in or giving the bond required by law.
Article 237: Prolonging Performance of Duties and Powers
• Elements:
1. The offender is a public officer.
2. They continue to exercise their duties and powers beyond the period provided by law.
• Who are the officers contemplated? This article applies to all public officers whose terms of
office are fixed by law.
Article 238: Abandonment of Office or Position
• Elements:
1. The offender is a public officer.
2. They abandon their office before their resignation is accepted.
3. The abandonment is to the detriment of the public service.
• Difference between abandonment of office and negligence and tolerance in prosecution of
offense (Art. 208):
o Abandonment of Office is a crime of non-performance, where a public officer completely
leaves their post.
o Negligence and Tolerance is a crime of dereliction of duty, where a public officer is still at
their post but fails to perform a specific duty.

Section 3: Usurpation of Powers and Unlawful Appointments

Article 239: Usurpation of Legislative Powers
• Elements: A public officer encroaches upon the powers of the legislative branch by making rules
beyond their authority or by attempting to repeal a law.
Article 240: Usurpation of Executive Functions
• Elements: A judge assumes any power pertaining to the executive authorities or obstructs them
in the lawful exercise of their powers.
Article 241: Usurpation of Judicial Functions
• Elements: An executive officer assumes any power pertaining to the judicial authorities or
obstructs them in the lawful exercise of their powers.
Article 242: Disobeying a Request for Disqualification
• Elements: A public officer continues a proceeding after being lawfully required to refrain from
doing so, and before the question of jurisdiction is decided.
Article 243: Orders or Requests by Executive Officers to a Judicial Authority
• Elements: An executive officer addresses an order or a suggestion to a judicial authority about a
case that is within the exclusive jurisdiction of the courts.
Article 244: Unlawful Appointments
• Elements: A public officer knowingly nominates or appoints a person to a public office who lacks
the legal qualifications for the position.
• Is the act of recommending punishable? No, the act of recommending a person for an
appointment is not punishable. The crime is committed only when the person is actually
appointed.

Section 4: Abuse Against Chastity

Article 245: Abuse Against Chastity
• Punishable acts:
1. A public officer, in a matter pending before them, solicits or makes immoral advances to a
woman interested in the matter.
2. A warden or public officer with custody of a prisoner solicits or makes immoral advances to
a woman under their custody.
• Elements:
1. The offender is a public officer.
2. They solicit or make immoral or indecent advances.
3. The person being solicited is a woman who is interested in a matter before the public
officer or is in their custody.
• Instances where abuse of chastity may arise: The crime can arise when a public officer takes
advantage of their official position to solicit a woman for sexual favors.

Anti-Graft and Corrupt Practices Act (R.A. 3019)

• Who are covered? This law covers all public officers, from the highest to the lowest, and their
relatives by consanguinity or affinity to the third degree.
• Punishable acts under Sec. 3 of R.A. 3019: The law lists 12 acts considered to be corrupt
practices, including:
1. Directly or indirectly requesting or receiving any gift, present, share, or percentage in
connection with any government contract or transaction.
2. Persuading, inducing, or influencing a public officer to violate rules or regulations.
3. Entering into a contract that is grossly and manifestly disadvantageous to the
government.
4. Knowingly approving or granting a license or a privilege that is not legally authorized.
 • Prohibited acts for private individuals: Private individuals who conspire with public officials to
commit any of the acts in Section 3 can also be held liable.
• Prohibited acts for the relatives: Relatives of public officers are also prohibited from taking
advantage of their family relations to gain an unfair advantage in government transactions.

People v. Henry T. Go (G.R. No. 168539, March 25, 2014)

• Case Digest: In this case, Henry T. Go, a private person, was charged with conspiring with a public
officer, then DOTC Secretary Arturo Enrile, to commit a crime under the Anti-Graft and Corrupt
Practices Act. Secretary Enrile died before the case was filed. Go argued that the case against him
should be dismissed because his co-conspirator was already deceased. The Supreme Court ruled
that a private person can be held liable for conspiracy even if the public officer they allegedly
conspired with is no longer a party to the case due to death. The death of the public officer
extinguishes their criminal liability, but it does not extinguish the crime itself or the basis for the
conspiracy charge against the private person.

Anti-Plunder Act (R.A. 7080, as amended)

• Who are covered? This law covers any public officer who, by himself or in connivance with his
family, relatives, or business associates, acquires ill-gotten wealth.
• Ill-gotten wealth: Any asset, property, business, or material possession that is acquired by a public
officer in an amount that is manifestly out of proportion to their lawful income.
• How is ill-gotten wealth acquired? It is acquired through a combination or series of overt or
criminal acts, such as misappropriation of public funds, receiving kickbacks, or other illegal
means.
• Plunder: The crime of a public officer amassing or accumulating ill-gotten wealth with a total
value of at least P50 million through a combination or a series of criminal acts.
• Combination: The commission of at least two of the acts enumerated in the law, such as
receiving a bribe and misappropriating public funds.
• Series: The repetition of the same act multiple times to acquire ill-gotten wealth.