Case Summary (G.R. No. L-60884)
Background of the Case
Petitioner was accountable for the supervision of numerous warehouses housing significant quantities of agricultural stocks, including corn grains, palay, rice, and corn grits. During an audit conducted on November 21, 1979, by a team from the Commission on Audit (COA), discrepancies were uncovered in his inventory accounts, revealing substantial shortages amounting to P4,438,151.05. Following additional evaluations and adjustments for tolerable allowances for damages, his total accountability was reduced to P3,900,961.39, with noted deficiencies in both stocks and empty sacks.
Summary of Prosecution Claims
The prosecution cited that under Article 217 of the Revised Penal Code, failure to account for public funds or property upon demand indicates prima facie evidence of malversation. The prosecution argued that the evidence substantiated the claim of misappropriation or embezzlement by the petitioner, asserting that he failed to provide a satisfactory explanation for the shortages. The reasonable excuse for the absence of public funds did not align with the findings from the COA audit.
Petitioner's Defense
In defense, the petitioner contended that the shortages resulted from various uncontrollable factors, such as poor storage conditions and infestation by insects and rodents. He sought to attribute the discrepancies to environmental factors rather than embezzlement or malfeasance, claiming that these issues should reasonably account for the reported losses.
Evaluation of Evidence and Findings
The court analyzed the credibility of the petitioner’s defenses and established that even if the storage conditions were inadequate, the extent of the shortages was excessive and could not be justified solely by environmental factors. Notably, the disappearance of empty sacks suggested potential theft or intentional misappropriation. The court found that significant volumes of accountable properties disappearing without human intervention were implausible and indicative of a larger issue of negligence or wrongdoing.
Legal Precedents and Applicability
The petitioner cited the case of Albores v. Court of Appeals to establish a precedent for his argument; however, the distinctions in circumstances were compelling. In contrast to his situation, the accused in Albor
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Case Overview
- This case involves a petition for certiorari assailing the decision dated June 7, 1982, by the Sandiganbayan, which found accused-petitioner Pedro Bacasnot y Caliao guilty beyond reasonable doubt of malversation of public funds/property.
- The decision rendered by the Sandiganbayan includes a sentence of 12 years and 1 day to 18 years, 8 months, and 1 day of reclusion temporal, along with perpetual special disqualification, a fine of P3,900,961.39, and an order to indemnify the National Food Authority (NFA) in the same amount.
Background of the Petitioner
- Pedro Bacasnot y Caliao served as the Operation Officer and Grains Stock Control Officer for the NFA in Bukidnon from May 1975 until his suspension in October 1980.
- He was an accountable officer required to post a bond, overseeing warehouses storing substantial quantities of corn grains, rice, and palay.
Audit Findings and Shortages
- On or about November 21, 1979, an audit by the Commission on Audit revealed significant shortages in Bacasnot’s accountabilities:
- Total shortages amounted to P4,438,151.05, broken down into various categories of grains and empty sacks.
- Following a reevaluation, the total shortage was adjusted to P3,900,961.39, which included an additional accountab