GR 255632; (July, 2023) (Digest)
G.R. No. 255632 . July 25, 2023
DANICA L. MEDINA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner Danica L. Medina was an employee of the Philippine Public School Teachers Association (PPSTA) assigned to its CAR Regional Office. She was charged with estafa under Article 315, paragraph (1)(b) of the Revised Penal Code. The Information alleged that between September 2011 and March 2012, she received a total of P88,452.00 from member-teachers as premium and membership fee payments, which she was obligated to deposit but instead misappropriated for her personal use. The prosecution presented witnesses, including PPSTA’s Chief Accountant and member-teachers, who testified that Medina received payments and issued acknowledgment receipts or statements of account but failed to remit the amounts to PPSTA. Medina denied the allegations, claiming she was never entrusted with money and was suddenly terminated. The Regional Trial Court found her guilty of estafa, a decision affirmed with modification by the Court of Appeals regarding the penalty. Medina elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the prosecution proved beyond reasonable doubt all the elements of estafa under Article 315, paragraph (1)(b) of the Revised Penal Code.
RULING
No. The Supreme Court acquitted petitioner Danica L. Medina. The prosecution failed to prove the elements of estafa. Specifically, it did not establish that the money received by Medina was “received in trust” for PPSTA. The evidence showed that the payments were made directly by the member-teachers to Medina for their own accounts, not consigned to PPSTA. Therefore, Medina did not have juridical possession over the funds as required for estafa. Furthermore, the prosecution failed to prove the element of taking or asportation required for qualified theft, as there was no evidence that the money was already in PPSTA’s possession before Medina allegedly took it. The Court emphasized that the prosecution must prove every element of the crime beyond reasonable doubt, which it failed to do in this case. The Decision and Resolution of the Court of Appeals were reversed and set aside. Medina was acquitted on the ground of reasonable doubt, and her cash bond was ordered released.