Case Digest (G.R. No. 224945) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Girlie J. Lingad was employed at the United Coconut Planters Bank (UCPB), Olongapo City Branch, from January 1, 1994 until April 19, 2004, as a marketing associate and branch marketing officer trainee with User ID “oloma01” and Teller ID No. 2840. She had authority to open, preterminate, and withdraw client accounts and placements. On April 19, 2004, she went on unauthorized absence and left for the United States. The Anti-Money Laundering Council (AMLC) investigated and found four sets of irregular transactions from July 2002 to April 2004 involving unauthorized preterminations and withdrawals of money-market placements and premium savings deposit (PSD) accounts belonging to UCPB clients. The funds—totaling over Php83 million—were credited to fictitious accounts, to accounts in the name of MV2 Telecoms, or to petitioner’s brother. On October 5, 2006, the Department of Justice filed an Information against Lingad for violating Section 4(a) of Republic Act No. 9160 (Anti-Money Lau... Case Digest (G.R. No. 224945) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Employment and Access
- Petitioner Girlie J. Lingad was employed by United Coconut Planters Bank (UCPB), Olongapo City Branch, from January 1, 1994 to April 19, 2004 as a marketing associate and branch marketing officer trainee.
- Her duties included opening, terminating, and withdrawing client accounts and money market placements; her position granted her access to the bank’s computer system (User ID “oloma01”, Teller ID 2840) and to cash and record vaults.
- Anomalous Transactions and AMLC Investigation
- On April 19, 2004, Lingad went AWOL; UCPB requested the Anti-Money Laundering Council (AMLC) to investigate her transactions.
- AMLC uncovered four series of unauthorized withdrawals and pre-terminations of money market and Premium Savings Deposit (PSD) accounts belonging mainly to William Chieng and Vittsi Tanjuakio amounting to approximately Php 83.3 million, transferred to fictitious accounts, client accounts under Chieng’s name, MV2 Telecoms, and Lingad’s brother.
- AMLC linked all transactions to petitioner’s User and Teller IDs; she left for the United States on April 20, 2004.
- Criminal Proceedings
- An Information was filed on October 5, 2006, charging Lingad with violating Section 4(a) of Republic Act No. 9160 (Anti-Money Laundering Act), as amended.
- She was extradited, arraigned, and pleaded not guilty. Trial ensued before RTC Branch 74, Olongapo City.
- Prosecution evidence: bank documents bearing Lingad’s signatures and system IDs, testimonies of Chieng and Tanjuakio denying consent or receipt of payment, AMLC findings showing the proceeds’ movement.
- Defense evidence: Lingad’s denials, claim of supervision by bank officers, limited authority over cash vaults, co-signature requirement on manager’s checks, lack of adverse audit findings.
Issues:
- Whether the prosecution proved beyond reasonable doubt all elements of money laundering under Section 4(a) of RA 9160, as amended.
- Whether Lingad’s acts constituted the predicate unlawful activity (qualified theft) necessary for money laundering.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)