G.R. No. L-1009
FACTS:
Ignacio Santa Maria, the elected president (municipal mayor) of Manaoag, Pangasinan, was previously the municipal treasurer. Upon his election, his son-in-law, Guillermo Patugnan, was appointed to fill the vacant treasurer position. On February 2, 1902, Santa Maria turned over the receipt books and cash to Patugnan. The official cashbooks were delivered on February 4, accompanied by an inventory showing the correct cash balance with no mention of any “vales” (IOUs). On February 9, during a cash recount, three “vales” totaling 157 pesos were found among the public funds, one of which was signed by Santa Maria. Excluding these vales, there was a shortage of 156.69 pesos. Patugnan had previously notified Santa Maria about the vales and demanded cash. Santa Maria appeared at the recount and tendered payment, which was refused. The prosecution alleged that Santa Maria misappropriated public funds by placing his personal IOU in the treasury. The defense contended that Patugnan maliciously took the vales from Santa Maria’s private desk and substituted them for cash to fabricate a case.
ISSUE:
Whether the evidence presented by the prosecution is sufficient to overcome the presumption of innocence and prove beyond reasonable doubt that Ignacio Santa Maria is guilty of misappropriation of public funds under Article 392 of the Penal Code.
RULING:
No. The Supreme Court reversed the judgment of the Court of First Instance. The Court held that the evidence was conflicting and did not preponderate so heavily against the accused as to overcome the constitutional presumption of innocence. Consequently, Ignacio Santa Maria was acquitted. The Court found it unnecessary to rule on the legal effect of his tender of payment. He was ordered discharged, with costs de oficio.