G.R. Nos. 249564 & 249568-76. March 21, 2022.
People of the Philippines, Plaintiff-Appellee, vs. Ma. Consuelo Toroba Palma Gil-Roflo, Jerico O. Ebita, Norman Jay Jacinto P. Doral, Derrick P. Andrade, Sergio U. Andrade and Chona Andrade Tolentino, Accused-Appellants.

FACTS

Accused-appellants were charged with violation of Section 3(e) of R.A. 3019 and Estafa Through Falsification of Public Documents. Ma. Consuelo T. Palma Gil-Roflo was a Sanggunian Panlalawigan member of Davao Oriental. The prosecution alleged that she conspired with her co-accused, who were presented as legitimate job order employees in her satellite office in Davao City, but were in truth her house helpers. Prosecution witness Rosie Bajenting, a former administrative aide in Roflo’s office, testified that she was instructed by Roflo to submit the names of the co-accused for job order contracts and to prepare and sign their Daily Time Records (DTRs) and Accomplishment Reports (ARs). Using these documents, salaries were collected from the provincial government. Bajenting further claimed she would claim the salaries via Special Power of Attorney and later deposit the money into Roflo’s personal bank account. The prosecution also presented evidence that accused Derrick and Sergio were enrolled as university students during their alleged employment. The defense countered that the accused were legitimate job order employees performing various tasks in a 24-hour satellite office providing public service. Roflo claimed the DTRs indicating 8:00 a.m. to 5:00 p.m. hours were prepared by staff and signed by the employees themselves, following HR department practice, and did not accurately reflect their actual round-the-clock work schedules.

ISSUE

The main issue was whether the Sandiganbayan correctly found accused-appellants guilty beyond reasonable doubt of the crimes charged.

RULING

The Supreme Court reversed the Sandiganbayan’s decision and acquitted all accused-appellants. The Court found that the prosecution failed to prove their guilt beyond reasonable doubt. For the violation of R.A. 3019, Section 3(e), the element of “evident bad faith” was not established. The prosecution relied heavily on the testimony of Bajenting, which was deemed unreliable due to her admitted animosity towards Roflo after being dismissed and charged with crimes by Roflo. Her testimony was uncorroborated and insufficient to overcome the presumption of innocence. The defense provided a credible explanation for the satellite office’s operations and the preparation of the DTRs. For Estafa Through Falsification, the prosecution failed to prove the element of falsity of the documents. The DTRs and ARs, while possibly inaccurate as to specific work hours, were not shown to be entirely fictitious, as the accused were indeed hired as job order employees who performed work. The defense’s claim that the indicated hours were a procedural formality to comply with payroll processing was not sufficiently rebutted. The Court emphasized that in criminal cases, the burden of proof lies with the prosecution, and any doubt must be resolved in favor of the accused.