G.R. No. 108670 - LBC Express, Inc. vs. Court of Appeals

Remedios Tanchanco y Pineda, the appellant, was employed by private complainant Atty. Rebecca Manuel y Azanza as a legal secretary and liaison officer.
Their relationship was notably close; having known each other for over 25 years, appellant was treated as part of Rebecca’s family, which helped establish a high degree of trust and confidence.

Between October 2000 and May 2001, appellant was entrusted with substantial cash amounts for processing the transfer of land titles for several of Rebecca’s clients.
The funds involved were meant to cover various taxes and fees, including capital gains tax, documentary stamp tax, transfer tax, and other expenses necessary for the processing of property transfers.
The Information specifically alleged that appellant took, and/or padded, sums amounting to a total of P417,922.90 or thereabout, to her own advantage.

Appellant was responsible for liquidating the expenses incurred when processing land titles, for which she prepared handwritten liquidation statements.
Evidence later revealed that many of the receipts submitted by the appellant were either fake or altered, thereby overstating the actual expenses incurred and masking the misappropriation.
Her abrupt abandonment of her duties on April 18, 2001 prompted Rebecca to review her records, which uncovered the discrepancies and financial irregularities.

In several transactions (involving properties of clients such as the Manongsong, Alviedo, Sundian, Sendino, and Mandrique properties), the amounts declared by appellant did not match the verified payments from banks and government agencies like the BIR and the Registry of Deeds.
Specific anomalies included:

Discrepancies in the donoras tax payments where appellant claimed to have paid a higher amount than what was certified by the Bank of Commerce.
Submission of fake or altered official receipts for payments of capital gains and documentary stamp taxes, as well as transfer taxes.
Inconsistencies in documented amounts, resulting in Rebecca having to cover additional expenses out of her own funds.

The Regional Trial Court (RTC) found appellant guilty beyond reasonable doubt of qualified theft, emphasizing the grave abuse of confidence inherent in the employer-employee relationship, and sentenced her to reclusion perpetua while ordering her to indemnify Rebecca.
The Court of Appeals (CA) subsequently affirmed the trial court’s decision but recalculated the total misappropriated amount to P248,447.45, based on a detailed examination of the transaction records and discrepancies noted in the liquidation statements.

Whether the trial court erred in convicting appellant of qualified theft despite the absence of direct evidence that she actually received the alleged funds.
Whether circumstantial evidence, presented in an unbroken chain, was sufficient to establish beyond reasonable doubt the taking of money from the complainant.

Whether the failure of the prosecution to produce direct evidence breached the presumption of innocence guaranteed to the appellant.
The weight to be accorded to mere denials by the appellant against the backdrop of overwhelming circumstantial proof.

The discrepancy between the complainant’s initial claim of P417,922.90 and the lower court’s computations (P407,711.68 by the RTC and P248,447.45 by the CA) and its impact on the determination of criminal liability.