G.R. No. 126995 , December 15, 1997, and October 6, 1998
IMELDA R. MARCOS, petitioner, vs. The Honorable SANDIGANBAYAN (First Division), and THE PEOPLE OF THE PHILIPPINES, respondents.

FACTS

This case involves a petition concerning the conviction of Imelda R. Marcos by the Sandiganbayan. The prosecution’s case relied heavily on documentary evidence showing a significant disparity between the monthly rental stipulated in a Lease Contract (Exhibit “B”) between the Light Rail Transit Authority (LRTA) and the Philippine General Hospital Foundation, Inc. (PGHFI), which was P102,760.00, and the monthly rental provided in a subsequent sublease agreement (Exhibit “D”), which was P734,000.00. The Court’s main Decision affirmed the conviction based on this “chasmic disparity.” A separate concurring opinion by Justice Bellosillo, however, scrutinizes the sufficiency of this evidence.

ISSUE

Whether the prosecution’s evidence, primarily the “chasmic disparity” in rental amounts between Exhibit “B” and Exhibit “D,” is sufficient to prove beyond reasonable doubt that the lease contract entered into by the petitioner was “manifestly and grossly disadvantageous to the government” under Section 3(g) of Republic Act No. 3019 , as amended.

RULING

Justice Bellosillo, in his concurring opinion, argues that the prosecution’s evidence is insufficient to establish guilt beyond reasonable doubt. The reasoning is as follows:
1. The mere “chasmic disparity” in rental amounts, by itself, is too tenuous and inadequate to prove that the Lease Contract (Exhibit “B”) was “manifestly and grossly disadvantageous to the Government.” The disparity alone does not connect to the criminal mind of the accused.
2. The Court’s prior acquittal of co-accused Jose P. Dans Jr., who signed Exhibit “B,” logically implies that Exhibit “B” was not found to be per se “manifestly and grossly disadvantageous to the Government.” Therefore, it is illogical to conclude that a subsequent agreement (Exhibit “D”) transformed the earlier contract into a grossly disadvantageous one without substantially changing its provisions.
3. The prosecution failed to sufficiently explain the reason behind the “extraordinary high” sublease rental. The high rental could be attributed to various speculative reasons (e.g., the sublessee’s personal motives or perceived potential of the property), not necessarily to criminal intent. When inculpatory facts are capable of interpretations consistent with innocence, the presumption of innocence must prevail.
4. The constitutional presumption of innocence is a matter of fact in this case due to the prosecution’s failure to meet the quantum of proof. A conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense.
5. While the leasing procedure may have been questionable, the evidence presented to prove criminal guilt was severely lacking. Consequently, the petitioner must be acquitted.
Based on this precept, Justice Bellosillo votes to grant the motion for reconsideration and reverse the petitioner’s conviction.