Case Summary (G.R. No. 205144)
Case Background
The petition for review on certiorari involves a judgment by the Court of Appeals affirming the Regional Trial Court's conviction of Margie Balerta for the crime of Estafa, with modifications on the penalty. The underlying charge alleges Balerta's misappropriation of funds while she was employed as a cashier for BABMPC. The Information filed against her outlined incidents from May 31, 1999, to June 17, 1999, wherein she was responsible for handling collections for the cooperative but allegedly misappropriated P185,584.06.
Prosecution's Version
During the trial, the prosecution relied on the testimony of its Manager, Timonera, who described Balerta's duties, including handling funds, making deposits, and administering loans in relation to CARE Philippines' account. Testimony revealed a significant discrepancy amount, suggesting Balerta had manipulated records and maintained two passbooks associated with her duties. An internal audit conducted in her absence indicated misappropriation, leading to accusations against her when discrepancies arose. Timonera also noted the failure of Balerta to return the demands for funds after repeated requests.
Defense's Position
Balerta testified that her last day at work was June 17, 1999, with subsequent claims of her medical condition influencing her absence. She argued that she had reminded Timonera of his significant cash advances and expressed suspicion regarding the motivations behind the accusations against her. Balerta claimed she lacked access to necessary documentation for her defense and that the audit conducted by Ambros was flawed, asserting without corroboration from additional witnesses.
RTC Ruling
The Regional Trial Court found Balerta guilty of Estafa by misappropriation, arguing her lack of credible evidence to substantiate her claims and emphasizing that her actions, like falsifying bank entries through manipulated records, demonstrated a clear intent to defraud BABMPC. The RTC sentenced her to imprisonment and mandated her to pay the alleged misappropriated funds.
CA Ruling
Balerta's appeal to the Court of Appeals addressed factual issues of misappropriation, focusing on whether she truly falsified records and whether the prosecution met its burden of proof. The CA upheld the RTC's decision but modified the penalties, reaffirming that the elements of Estafa were sufficiently proven by the prosecution.
Supreme Court's Ruling
Upon review, the Supreme Court found merit in Balerta's petition and reversed the previous judgments. The Court concluded that Balerta did not possess "juridical possession" over the funds, receiving them merely as
...continue readingCase Syllabus (G.R. No. 205144)
Case Summary
- The case involves a petition for review on certiorari filed by Margie Balerta against the People of the Philippines, challenging the decisions rendered by the Regional Trial Court (RTC) and the Court of Appeals (CA) regarding her conviction for the crime of Estafa.
- The RTC found Balerta guilty of Estafa through misappropriation, sentencing her to a prison term and ordering her to pay restitution.
- The CA affirmed the RTC’s decision with modifications regarding the penalty imposed.
Antecedents
- An Information dated October 27, 1999, was filed against Balerta, accusing her of misappropriating funds while employed as a cashier for the Balasan Associated Barangays Multi-Purpose Cooperative (BABMPC).
- The prosecution alleged that Balerta misappropriated a total of PHP 185,584.06 from the cooperative, failing to account for or return the funds despite repeated demands.
Version of the Prosecution
- During pre-trial, the prosecution stipulated on key facts regarding the identity of the cooperative and Balerta’s role as cashier.
- Testimony was primarily provided by Napoleon Timonera, the cooperative's manager, who outlined Balerta's duties and the financial discrepancies that led to the complaint.
- The prosecution established that Balerta had access to cooperative funds but failed to present documentary evidence during the trial.