Case Summary (G.R. No. 164375)
Antecedent Facts
Joenil Pin Molde was charged with qualified theft defined under Article 310, in relation to Article 308, of the Revised Penal Code (RPC). The charge stemmed from an incident occurring on May 26, 2010, where Molde, serving as the Accounting-in-Charge at Sun Pride Foods, was accused of stealing PHP 1,149,960.56 from the company. Molde pleaded not guilty during his arraignment, which occurred on November 15, 2010.
Version of the Prosecution
The prosecution's narrative depicted Molde as having significant responsibilities at Sun Pride, particularly managing cash transactions and overseeing deposits to the company’s bank account. An investigation initiated by the company's head of accounting revealed that Molde had failed to remit cash collections totaling PHP 1,149,960.56, which triggered a series of demand letters and ultimately his suspension when he resigned shortly thereafter.
Version of the Defense
Molde refuted the allegations, asserting that he did not pocket any cash or checks since he was not authorized to encash checks issued to Sun Pride. He contended that the cash deposited in the bank was done directly by the sales agents, and he merely collected accompanying documentation like deposit slips.
Ruling of the Regional Trial Court
The RTC found Molde guilty of qualified theft. The court stated that as the Accounting-in-Charge, he was authorized to manage cash collections, making his failure to remit significant amounts a breach of trust. The RTC sentenced Molde to reclusion perpetua and ordered him to pay restitution to Sun Pride.
Ruling of the Court of Appeals
The Court of Appeals affirmed the RTC’s decision, reinforcing that the prosecution met its burden of proof. The CA noted inconsistencies in Molde's defense, highlighting that his denial of receiving cash and checks diminished his credibility, particularly as he initially admitted to receiving these funds during cross-examination.
The Issue
Molde appealed the CA’s decision, raising a singular issue concerning whether his guilt was proven beyond reasonable doubt, particularly contesting the prosecution's evidence that he had pocketed the missing cash and checks.
The Court's Ruling
The Supreme Court's analysis focused on the elements required for a conviction for qualified theft. The Court concluded that the prosecution failed to demonstrate beyond a reasonable doubt that Molde took personal property with intent to gain. It particularly noted that since the checks were ma
...continue readingCase Syllabus (G.R. No. 164375)
Case Information
- Citation: 845 Phil. 858
- Division: FIRST DIVISION
- Case Number: G.R. No. 228262
- Decision Date: January 21, 2019
- Parties: People of the Philippines (Plaintiff-Appellee) vs. Joenil Pin Molde (Accused-Appellant)
Introduction
- This syllabus summarizes the decision of the Supreme Court regarding the appeal of Joenil Pin Molde against the ruling of the Court of Appeals, which upheld his conviction for qualified theft.
Antecedent Facts
- Charge: Joenil Pin Molde was charged with qualified theft under Article 310 in relation to Article 308 of the Revised Penal Code.
- Date of Incident: May 26, 2010.
- Context: Molde was employed as the Accounting-in-Charge of Sun Pride Foods, Inc. at their Las Piñas City branch. He had custody over cash collections and checks.
- Allegation: The Information highlighted that Molde unlawfully took Php1,149,960.56, which belonged to Sun Pride Foods, Inc., without the knowledge and consent of the complainant, Henry Dy.
- Plea: During his arraignment on November 15, 2010, Molde pleaded not guilty.
Version of the Prosecution
- Employment Background: Molde was hired in 2006 and became the accounting-in-charge in February 2008 at the Las Piñas branch.
- Duties: His responsibilities included receiving cash and check collections and remitting these to Sun Pride's bank account.
- Discovery of Theft: An investigation prompted by low cash remittances revealed a shortfall of Php1,149,960.56 due to unremitted cash and checks.
- Demand for Payment: After the audit, Sun Pride sent demand letters to Molde, which he ignored, leading to his suspension.
- Resignation: Molde submitted a resignation letter, which Sun Pride refused t