De Jesus vs.

Sandiganbayan

G.R. No. 164166 & 164173-80

Oct 17, 2007

Facts: Rodolfo S. De Jesus and Edelwina Parungao, Being the Deputy Administrator and Manager, HRMD,
of the Local Water Utilities Administration (LWUA) falsified the public document of the appointment of
Jesusito R. Toren, a confidential staff of the Trustees of the LWUA, when they made it appear that the
appointment was signed on October 15, 2001 when the appointee was officially appointed on Dec. 12,
2001, allowing the appointee to receive salaries and allowances for a period when they were not
officially appointed.

Petitioner and Parungao filed a motion to quash that the Sandiganbayan lacked jurisdiction over the
offense charge when the allegations of fact did not constitute the offense.

Sandiganbayan ruled that the appointing power and the function of preparing the documents were
inherent in the position of petitioner and Parungao, to which they allegedly issue and approve
appointment papers.

Sandiganbayan denied the motion to quash and the petitioner sought reconsideration but was denied.

Issue:

Whether or not the resolutions of the Sandiganbayan denying the petitioner’s motion to quash were
issued with grave abuse of discretion amounting to lack or excess of jurisdiction?

Whether the petitioner and Parungao falsify the public document in the appointment papers?

Ruling:

Yes, the Sandiganbayan erred the petitioner’s motion to quash with grave abuse of discretion amounting
to lack or excess of jurisdiction. The Court held that there was no reasonable ground to believe that the
Petitioner and Parungao committed the offense of falsification, since the elements of the offense were
not present and that there was no criminal intent or mens rea. The Court also noted that the
Sandiganbayan had granted de Jesus' motion for reinvestigation, indicating that it was willing to accept
the final resolution of the Ombudsman on the issue of whether the offense was committed. As a result,
the Court annulled the resolutions of the Sandiganbayan and ordered the dismissal of the criminal cases
against de Jesus.
Batulanon vs. People

G.R. No. 139857

Sep 15, 2006

This involves Criminal Case Nos. 3453, 3625, 3626, and 3627, convicting Leonila Batulanon of Estafa
through falsification of commercial documents for misappropriating loans by forging signatures and
falsely recording transactions.

Facts:

The case involves Leonila Batulanon, the former Cashier/Manager of Polomolok Credit Cooperative
Incorporated (PCCI). Batulanon was convicted of Estafa and falsification of commercial documents. The
case originated from an audit conducted in December 1982, which revealed irregularities in the release
of loans. Four informations for Estafa through falsification of commercial documents were filed against
Batulanon. The trial court convicted Batulanon and sentenced her to 4 months of arresto mayor to 1
year and 2 months of prision correccional for each case. The Court of Appeals affirmed the decision with
modification, imposing a penalty of 6 months of arresto mayor to 4 years and 2 months of prision
correccional for each case. Batulanon appealed to the Supreme Court, arguing that the prosecution
should have presented the alleged victims as witnesses and that PCCI was not prejudiced by the loan
transactions.

Issue:

The main issues raised in the case are:

Whether the prosecution should have presented the alleged victims as witnesses?

Whether PCCI was prejudiced by the loan transactions?

Ruling:

The Supreme Court held that the prosecution was not required to present the alleged victims as
witnesses. The Court explained that the prosecution had sufficiently proven the elements of the crimes
charged through documentary evidence and testimonies of other witnesses. The Court emphasized that
presenting the alleged victims as witnesses was not necessary for the conviction of Batulanon.

Regarding the issue of prejudice to PCCI, the Court found that Batulanon's misappropriation of loans and
falsification of documents caused damage to PCCI. The Court noted that Batulanon's act of forging
signatures and falsely recording transactions resulted in the release of loans to unauthorized borrowers.
This misappropriation of funds entrusted to her caused financial loss to PCCI. Therefore, the Court
concluded that PCCI was indeed prejudiced by the loan transactions.

Based on these findings, the Supreme Court affirmed Batulanon's conviction for falsification of private
documents and estafa. The Court upheld the penalties imposed by the lower courts, considering the
gravity of Batulanon's offenses. Additionally, the Court ordered Batulanon to indemnify PCCI for the
amount misappropriated, with interest, to compensate for the damage caused by her actions.
Domingo vs. People

G.R. No. 186101

Oct 12, 2009

Dentist Gina Domingo is convicted of Estafa through Falsification of Commercial Document after forging
encashment slips and withdrawing money from a businesswoman's bank account, leading to her
imprisonment and restitution.

Facts:

The case involves the conviction of dentist Gina Domingo for Estafa through Falsification of Commercial
Document where Domingo was found guilty of 17 counts of Estafa. The court found that Domingo had
forged encashment slips and withdrew money from the bank account of Remedios Perez, a
businesswoman and valued depositor of the Bank of the Philippine Islands (BPI). The withdrawals
amounted to a total of Php 838,000. The court also found that Domingo had deposited some of the
money into her account and paid the rest to Skycable.

The transactions were processed by four tellers of BPI, who verified the signatures on the encashment
slips. After discovering the illegal transactions, Perez complained to the bank and demanded the return
of the money. The bank agreed to pay her Php 645,000, representing a portion of the amount illegally
withdrawn. Domingo denied the charges and claimed that the signatures on the encashment slips were
not hers.

Issue:

The main issue raised in the case is whether or not Domingo is guilty of Estafa through Falsification of
Commercial Document.

Ruling:

The court ruled that Domingo is guilty of Estafa through Falsification of Commercial Document.

The court found that all the elements of the crime of Falsification of Commercial Document were
present in this case. Domingo had forged the encashment slips and used them to withdraw money from
Perez's bank account. The court also found that the falsification was a necessary means to commit
Estafa, as Domingo used the forged documents to deceive the bank and unlawfully obtain the money.

Domingo's defense of denial was rejected by the court, as it was unsubstantiated by clear and convincing
evidence. The court noted that the signatures on the encashment slips were verified by four tellers of
BPI, and there was no evidence to suggest that the tellers were mistaken or that the signatures were not
genuine.

The court affirmed the decision of the RTC, which found Domingo guilty of 17 counts of Estafa.
Domingo's appeal was denied, and she was ordered to pay the remaining amount of Php 193,000 to
Perez.
Mangulab vs. People

G.R. No. 236848

Jun 8, 2020

A court interpreter is convicted of direct bribery after demanding and receiving money on behalf of a
judge in exchange for a favorable decision in an election protest case, resulting in imprisonment, a fine,
and temporary disqualification from holding public office.

Facts:

The case of Mangulabnan v. People involves the conviction of Candelaria De Mesa Mangulabnan for
direct bribery. The prosecution alleged that Mangulabnan, who worked as a court interpreter, acted as a
conduit for Judge Flores in demanding and receiving P20,000 from Dario Manalastas, a party to an
election protest case. The money was given in exchange for a favorable decision in the case. The case
was referred to Executive Judge Adelaida Ala-Medina for investigation, and she recommended
Mangulabnan's dismissal from service. The Office of the Ombudsman found that the allegations
constituted direct bribery and filed an information against Mangulabnan. During the trial, the
prosecution did not present any witnesses but relied on the documents from the administrative case.
Mangulabnan filed a motion for leave to file demurrer to evidence, which was denied. She then filed an
ex-parte manifestation waiving her right to present evidence. The Sandiganbayan (SB) found
Mangulabnan guilty beyond reasonable doubt of direct bribery and sentenced her to imprisonment, a
fine, and temporary disqualification from holding public office. Mangulabnan filed a motion for
reconsideration, which was denied. She then filed a petition for review on certiorari before the Supreme
Court.

Issue:

The main issue before the Court was whether the SB correctly convicted Mangulabnan of direct bribery
under Article 210 of the Revised Penal Code.

Ruling:

The Court ruled that the petition was without merit and affirmed the SB's decision. The Court held that
the elements of direct bribery were sufficiently established in this case. Mangulabnan's conspiracy with
Judge Flores was proven by the findings of the investigating judge and Mangulabnan's own admission.
The Court also found that all the elements of direct bribery were present, including the fact that
Mangulabnan acted as a conduit for Judge Flores in receiving money from Manalastas and delivering it
to the judge.

The Court rejected Mangulabnan's argument that administrative accountability cannot amount to a
finding of guilt in a criminal case. The Court emphasized that administrative accountability and criminal
liability are distinct and separate. The Court held that the administrative case against Mangulabnan
merely served as evidence to establish her guilt in the criminal case, and it was not the sole basis for her
conviction.

The Court also held that Mangulabnan was given ample opportunity to present evidence but voluntarily
waived her right to do so. Therefore, the SB's reliance on the documentary evidence from the
administrative case was justified. The Court concluded that there was no reason to overturn the SB's
findings, as there was no showing that the SB overlooked or misapplied the facts and circumstances of
the case.

In light of these considerations, the Court affirmed Mangulabnan's conviction for direct bribery and
upheld the imposed penalties, including imprisonment, a fine, and temporary disqualification from
holding public office.
Formilleza vs. Sandiganbayan

G.R. No. 75160

Mar 18, 1988

A personnel supervisor is accused of accepting a bribe, but is ultimately acquitted due to lack of
evidence and inconsistencies in the prosecution's case.

Facts:

The case involves Leonor Formilleza, a personnel supervisor at the regional office of the National
Irrigation Administration (NIA) in Tacloban City, Leyte. She was accused of accepting a bribe from Mrs.
Estrella Mutia, an employee of the NIA, in exchange for expediting the processing of Mutia's
appointment papers. Mutia reported the alleged bribery to the Philippine Constabulary (PC) authorities,
who then organized an entrapment operation. During the entrapment, Mutia handed marked money
bills to Formilleza under the table, which was witnessed by PC operatives. Formilleza was subsequently
arrested and charged with direct bribery.

The Sandiganbayan, the anti-graft court, found Formilleza guilty of indirect bribery instead of direct
bribery, based on the evidence presented during the trial. The court ruled that the essential element of
indirect bribery, which is the acceptance of the gift or material consideration by the public officer, was
proven. Formilleza was sentenced to four months of arresto mayor, suspension from public office, and
public censure.

Issue:

The main issue raised in the case is whether the Sandiganbayan's conclusion that Formilleza is guilty of
indirect bribery is supported by the evidence presented during the trial. Additionally, the applicability
and correctness of a previous ruling in People v. Abesamis, which the Sandiganbayan relied on in
convicting Formilleza, is also disputed.

Ruling:

The Supreme Court, in reviewing the case, emphasized that only questions of law can be raised in a
petition for certiorari under Rule 45. However, the court recognized that there are exceptions to this
general rule, such as when the findings of fact made by the trial court overlooked certain facts that could
affect the result of the case. In this case, the court found that there were substantial facts and
circumstances that were favorable to Formilleza but were not carefully considered by the
Sandiganbayan.

The Supreme Court specifically focused on the requirement of accepting the bribe money as an essential
element of indirect bribery. It noted that the photographs taken during the entrapment operation did
not show Formilleza in the process of appropriating or keeping the money after it was handed to her. The
court also considered the presence of other individuals, including Formilleza's officemate, Mrs. Sevilla,
who did not witness the alleged passing of the money. Based on these observations, the court concluded
that there was not enough evidence to prove Formilleza's guilt beyond reasonable doubt.

As a result, the Supreme Court set aside the decision of the Sandiganbayan and acquitted Formilleza on
the basis of reasonable doubt. The court emphasized that moral certainty, not absolute certainty, is
needed to support a judgment of conviction.
People vs. Enguero

G.R. No. L-8922-24

Feb 28, 1957

Four defendants are convicted and sentenced for three separate robberies in band, after tying up
occupants, stealing various items and money, and demanding money and jewelry from different houses
in Lupi, Camarines Sur.

Facts:

The case of People v. Enguero involves four defendants, namely Florentino Enguero, Jose Tariman,
Nazario Narvete, and Dionisio Bueno. The crimes took place in Lupi, Camarines Sur. The defendants were
convicted and sentenced for three separate robberies in band. During the commission of the crimes, the
defendants tied up the occupants of the houses they targeted, stole various items and money, and
demanded money and jewelry.

Issue:

The main issue raised in the case is whether the defendants should be convicted and sentenced for three
separate robberies in band or only one.

Ruling:

The court ruled that the defendants should be convicted and sentenced for three separate robberies in
band.

The court based its decision on the case of People v. De Leon, which involved a defendant who stole two
fighting cocks from different owners. In that case, the defendant was only convicted and sentenced for
one crime. However, in the present case, the defendants committed three separate robberies in band,
going from one house to another and demanding money and jewelry. Therefore, the rule in People v. De
Leon does not apply.

The court's decision is also based on the pertinent provisions of the Revised Penal Code. The defendants
committed multiple robberies in band, which is a crime punishable under article 294, paragraph 5, of the
Revised Penal Code. The penalty for this crime is prision mayor in its medium period, which ranges from
3 years and 1 day to 10 years.
Realiza vs. People

G.R. No. 228745

Aug 26, 2020

Carlu Alfonso A. Realiza is found guilty of theft and sentenced to community service instead of
imprisonment after the Supreme Court upholds the lower courts' findings of guilt based on the
credibility of witnesses and the successful establishment of all elements of the crime.

Facts:

Carlu Alfonso A. Realiza was charged with theft. The charge stemmed from an incident on January 7,
2011, where Realiza allegedly stole a pair of rubber boots, an iron pot, and a frying pan from the house
of Elfa L. Boganotan. Elfa's son, Kim Boganotan, witnessed the theft and reported it to his parents.
Realiza denied the accusation and claimed that he was in a different location at the time of the incident.

After the trial, the MTCC found Realiza guilty of theft and sentenced him to imprisonment. Realiza
appealed the decision to the Regional Trial Court (RTC), which affirmed the MTCC's ruling. Realiza then
filed a petition for review with the Court of Appeals (CA), which also affirmed the lower courts' decision.

Issue:

The main issue in the case is whether or not Realiza's guilt was established beyond reasonable doubt.

Ruling:

The Supreme Court found no merit in Realiza's petition and upheld the lower courts' findings.

The Court emphasized that the credibility of witnesses is accorded great weight and respect, especially
when affirmed by the appellate court. In this case, the trial court gave full credence to Kim Boganotan's
testimony, which directly implicated Realiza in the theft. The Court found no glaring errors or
misapprehension of facts in the lower courts' findings.

Realiza argued that Kim was not a credible witness and that his testimony was fabricated due to a
conflict between Realiza and his uncle. However, the Court found that the evidence on record fully
supported the trial court's factual finding, as affirmed by the CA.

Regarding Realiza's defense of alibi, the Court held that it was inherently weak. While Realiza provided
evidence that he was in a different location at the time of the incident, the Court believed that he had
enough time to commit the theft before leaving. The positive identification of eyewitnesses outweighed
Realiza's defense.

The Court concluded that all the elements of theft were successfully established by the prosecution.
Realiza took the personal belongings of Elfa without her consent, with the intention to gain, and without
violence or intimidation. Therefore, the Court affirmed the lower courts' finding of guilt.

In conclusion, the Supreme Court affirmed the lower courts' findings of guilt against Realiza for theft. The
Court upheld the credibility of witnesses and the successful establishment of all elements of the crime.
Realiza was sentenced to community service instead of imprisonment under R.A. No. 10951.
People vs. Manlao y Laquila

Case

G.R. No. 234023

Sep 3, 2018

A housemaid is found guilty of qualified theft after stealing jewelry from her employers, resulting in a
prison sentence and the obligation to pay restitution.

Facts:

This case involves the conviction of Jennie Manlao y Laquila for qualified theft. The RTC found Jennie
guilty of qualified theft and sentenced her to reclusion perpetua, as well as ordering her to pay
restitution to the victim. The CA affirmed the RTC's decision.

The facts of the case are as follows: Jennie was employed as a housemaid by Carmel Ace Quimpo-
Villaraza and her husband. On July 1, 2011, Geralyn, another housemaid, noticed Jennie talking on the
phone and crying. When Geralyn asked her about it, Jennie claimed that their employers had been in an
accident. Geralyn later found Jennie opening the bathroom drawer with a knife, screwdriver, and
hairpins. Jennie explained that Carmel had instructed her to look for dollars in the drawer. Jennie then
took Carmel's jewelry and left the house. Carmel and her husband tried to contact their housemaids but
were unable to reach them. They eventually learned from Geralyn that Jennie had taken the jewelry and
left the house. Jennie was later apprehended and admitted to taking the jewelry.

Issue:

The main issue before the court was whether or not Jennie was guilty beyond reasonable doubt of
qualified theft.

Ruling:

The court ruled that the appeal was without merit and affirmed Jennie's conviction. The court held that
the prosecution had established all the elements of qualified theft and found no reason to deviate from
the factual findings of the trial court. The court also applied the provisions of Republic Act No. 10951,
which adjusted the penalties for theft, and sentenced Jennie to an indeterminate period of
imprisonment. The court ordered Jennie to pay restitution to the victim, with legal interest.

The court held that all the elements of qualified theft were present in this case. These elements include
the taking of personal property belonging to another, the intent to gain, the absence of the owner's
consent, and the absence of violence or intimidation. The court found that Jennie's intent to gain could
be presumed from her overt acts, such as calmly opening the drawer and deliberately deviating from
Carmel's instructions regarding scammers. The court rejected Jennie's claim of being tricked, finding it
illogical given Carmel's warning against scammers.

The court also found that the prosecution had established the intent to gain, which could be presumed
from the proven unlawful taking. The court found no error in the RTC's reduction of the value of the
stolen items based on pictures presented in court.
In conclusion, Jennie Manlao y Laquila was found guilty beyond reasonable doubt of qualified theft. The
court affirmed her conviction and sentenced her to imprisonment and restitution.

The Defendants were accused of dangerous drugs and possession of dangerous drugs during a social
gathering, in violation of R.A. No. 9165 or the Comprehensive Dangerous Drugs Act of 2002.

Facts:

On June 10, 2011, the police received information about an ongoing pot session at an abandoned nipa
hut in Dagupan City. Without undertaking any prior surveillance or verification, police officers went to
the hut and found the defendants inside. The police entered the hut and arrested the defendants
without seeing any overt acts of their involvement in illegal drug activities. The police then searched the
table and the suspects' pockets, discovering plastic sachets carrying suspected shabu. The seized items
were not promptly marked and inventoried in the presence of the defendants and their witnesses. The
marking up and inventory were only completed at the police station. The seized items were later
analyzed and found to contain hazardous substances.

Issues:

1. Whether the defendants were placed in double jeopardy by being charged and convicted of both
possession of dangerous drugs and possession of dangerous drugs during a social gathering.

2. Whether the warrantless arrest and search of the defendants were valid?

Ruling:

the Supreme Court emphasized the importance of upholding constitutional rights and proper procedures
in the criminal justice system. The Court highlighted that the right against unreasonable searches and
seizures is sacred and must prevail over the campaign against illegal drugs. Under Article III, Section 2 of
our Constitution, The general rule is that no arrest, search, and seizure can be made without a valid
warrant issued by a competent judicial authority. A person's right to be secure against unreasonable
searches and seizures is sacred in this jurisdiction. Any evidence resulting from a violation of a person's
right against unreasonable searches and seizures will be deemed inadmissible in court.

The Court further emphasized that law enforcement officers must have personal knowledge of the
commission of a crime or witness an overt act indicating the involvement of the defendants in illegal
drug activities for a warrantless arrest and search to be valid.

In this case, there was no in flagrante delicto arrest. The Police Officers failed to comply with this
requirement about the authenticity and integrity of the seized items, which may lead to their exclusion
as evidence. There was no probable cause to justify the barging of the buy-bust team into the nipa hut
where accused-appellants were privately gathered, and their subsequent arrest of accused-appellants.

Therefore, they are acquitted.