Ignacio Arroyo v. Alfred Berwin

Summary

This 1917 Supreme Court case established that contracts to dismiss criminal proceedings in exchange for valuable consideration are void for illicit consideration. Ignacio Arroyo sued Alfred Berwin, a procurador judicial, to enforce an agreement where Berwin's client would recognize Arroyo's land ownership if Arroyo secured dismissal of theft charges against her. While Arroyo fulfilled his part by getting the criminal case dismissed, Berwin refused to deliver the promised written acknowledgment. The Supreme Court affirmed the trial court's dismissal, ruling that such agreements violate public policy by allowing criminals to purchase immunity from prosecution. The decision reinforced that all criminal proceedings must follow prescribed legal procedures and cannot be compromised through private arrangements, regardless of the consideration offered.