G.R. No. 177874 - Ang vs. Court of Appeals

Background of the Case: The case involves petitioners Zacaria A. Candao, Abas A. Candao, and Israel B. Haron, who were officials of the Office of the Regional Governor, Autonomous Region for Muslim Mindanao (ORG-ARMM). They were charged with malversation of public funds under Article 217 of the Revised Penal Code, as amended.
Audit Findings: A Commission on Audit (COA) team conducted an expanded special audit of ORG-ARMM from August 24 to September 1, 1993, covering the period July 1992 to March 1993. The audit revealed illegal withdrawals totaling ₱21,045,570.64 through 52 checks issued without the required disbursement vouchers.
Details of the Transactions: The checks, signed by the petitioners, were encashed without proper documentation. The audit team found that the disbursement vouchers were missing, and the checks were not supported by the necessary paperwork.
Demand for Restitution: COA Chairman Pascasio S. Banaria demanded that petitioner Haron restitute the misappropriated funds and provide an explanation within 72 hours. Haron failed to comply with this demand.
Criminal Charges: On April 17, 1998, the Office of the Ombudsman-Mindanao filed multiple counts of malversation against the petitioners.

Whether the petitioners were denied due process in their conviction for malversation due to the alleged existence of disbursement vouchers that the COA refused to examine.
Whether the Sandiganbayan erred in not applying the "equipoise rule," which could have resulted in the acquittal of the petitioners.
Whether the Sandiganbayan erred in convicting Zacaria A. Candao and Abas A. Candao despite the lack of sufficient proof of conspiracy.