Facts:

• Margie Balerta (petitioner) was employed as a cashier for the Balasan Associated Barangays Multi-Purpose Cooperative (BABMPC) in Balasan, Iloilo, Philippines.
• On October 27, 1999, she was charged with Estafa for allegedly misappropriating PHP 185,584.06 between May 31, 1999, and June 17, 1999.
• Balerta pleaded not guilty during her arraignment, and a pre-trial was conducted where her role and the cooperative's structure were established.
• The prosecution's case relied on testimonies from BABMPC's Manager, Napoleon Timonera, and Internal Auditor, Ruben Ambros, who claimed discrepancies in Balerta's records were discovered during an internal audit.
• Balerta ceased reporting for work after the discrepancies were noted, and the defense argued that the audit was conducted without her presence and that she had no control over the funds.
• The Regional Trial Court (RTC) found her guilty of Estafa on November 15, 2006, sentencing her to imprisonment and ordering restitution to the cooperative.
• Balerta appealed to the Court of Appeals (CA), which affirmed the RTC's decision with modifications to the penalty.

Issue:

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Ruling:

• The Supreme Court granted the petition and reversed the Court of Appeals' decision.
• Margie Balerta was acquitted of Estafa under Article 315(1)(b) of the Revised Penal Code.
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Ratio:

• The Supreme Court focused on whether Balerta had juridical possession of the funds, clarifying that juridical possession entails a right over property that can be asserted against the owner, while mere material possession does not.
• Balerta was found to have only material possession of the funds, similar to a bank teller, who lacks independent rights over the money handled.
• The prosecution did not sufficiently establish the elements of Es...continue reading