Case Summary (G.R. No. 152119)
Petitioner’s Arraignment and Trial
Baylosis was arraigned for the crime of estafa and entered a plea of not guilty. His trial proceeded in absentia, as he failed to appear despite being out on bail. The prosecution presented two witnesses who testified regarding the misappropriation of funds. Key details included Baylosis’s confession of taking PhP 90,000 from company collections and misreporting the amount due. Subsequently, a cash count revealed a total shortage of PhP 118,181.71, acknowledged by Baylosis through his signature on the cash count sheet.
Administrative Consequences for Petitioner
Following the confession and cash shortage findings, Baylosis was suspended from service and subjected to an administrative investigation. His non-appearance in scheduled hearings led to his dismissal based on presented documentary evidence and a notice of termination due to his misconduct.
Initial Court Decision
On January 10, 1992, the Cebu City RTC found Baylosis guilty beyond a reasonable doubt of the crime of estafa and sentenced him to an indeterminate prison term ranging from seven years of prision mayor to seventeen years of reclusion temporal, along with a directive to indemnify PCPPI the total amount of PhP 118,181.71.
Motion for Reconsideration
Following his conviction, Baylosis filed a Motion for Reconsideration, which the trial court denied, prompting him to file a Notice of Appeal.
Motion for New Trial
Baylosis subsequently filed a Motion for New Trial with the Court of Appeals (CA), supported by an affidavit from Zenaida C. Aya-ay, which stated his outstanding liability had been reduced to PhP 21,981.71. He sought to remand the case for a new trial and to change his plea to guilty.
Court of Appeals' Resolutions
The CA denied Baylosis's Motion for New Trial on December 5, 2001, for lack of merit, concluding that the evidence presented by Aya-ay concerning payments made after the original judgment could not be classified as newly discovered evidence. This ruling was affirmed when Baylosis’s Motion for Reconsideration was also denied on February 8, 2002.
Supreme Court's Assessment of the Motion for New Trial
The Supreme Court found that for a motion based on newly discovered evidence to be granted, it must meet specific criteria. The evidence must have been discovered post-trial; it must be
...continue readingCase Syllabus (G.R. No. 152119)
Background of the Case
- This case involves a Petition for Review on Certiorari under Rule 45, challenging the December 5, 2001 Resolution of the Court of Appeals (CA) regarding a Motion for New Trial filed by Francisco L. Baylosis, Sr.
- Baylosis was convicted of estafa, with the CA denying his request to change his plea to guilty and reduce the amount misappropriated to PhP 21,981.71.
- The February 8, 2002 CA Resolution denying Baylosis' Motion for Reconsideration was also assailed.
Facts of the Case
- An Information was filed against Baylosis for estafa before the Cebu City Regional Trial Court (RTC), citing misappropriation of funds while serving as a warehouse supervisor for Pepsi-Cola Products Philippines, Inc. (PCPPI).
- The alleged misappropriation occurred from February 1990 to March 5, 1990, involving a total of PhP 118,181.71.
- During arraignment, Baylosis pleaded not guilty, but trial proceeded in absentia as he failed to appear.
- Key prosecution witnesses included Ricardo Tabasa, the Warehouse Operations Manager, and Leopoldo Abella, the Route Manager, both testifying about the misappropriation and Baylosis’ subsequent confession.
- On March 5, 1990, Baylosis confessed to using the misappropriated funds for a "special project" and later acknowledged the cash shortage during an inventory.
- Following his confess