GR 70168 69; (July, 1996) (Digest)
G.R. Nos. 70168-69 July 24, 1996
RAFAEL T. MOLINA and REYNALDO SONEJA, petitioners, vs. THE PEOPLE OF THE PHILIPPINES and the HON. INTERMEDIATE APPELLATE COURT, respondents.
FACTS
Petitioners Rafael Molina (Assistant Provincial Auditor) and Reynaldo Soneja (Hospital Cashier), along with other co-accused, were charged with Estafa through Falsification of Public Documents and Violation of Section 3(h) of the Anti-Graft and Corrupt Practices Act (R.A. 3019). The charges stemmed from a conspiracy to simulate a transaction wherein the JMA Memorial Hospital purportedly purchased medical supplies worth P7,610.00 from D’Vinta Marketing Center. The prosecution established that no such supplies were delivered. The accused falsified requisition vouchers, canvass papers, and other public documents to facilitate the issuance of two treasury checks payable to D’Vinta Marketing Center.
The evidence showed that Molina approached the proprietor’s wife to secure a blank invoice and later to endorse the treasury checks, but she refused. The checks were subsequently endorsed and cashed by the accused. The prosecution presented documentary evidence of the falsified vouchers and the testimony of the proprietor, Homer Tabuzo, who denied any transaction with the hospital. The trial court convicted the petitioners, and the Intermediate Appellate Court affirmed the conviction.
ISSUE
The core issue is whether the prosecution proved the guilt of the petitioners beyond reasonable doubt for the complex crime of Estafa through Falsification of Public Documents and for violating R.A. 3019, Section 3(h).
RULING
The Supreme Court affirmed the convictions. On the charge of Estafa through Falsification, the Court held that all elements were present: (1) the accused falsified public documents by simulating a purchase; (2) the falsification was the efficient means to commit estafa; and (3) the government was defrauded of P7,610.00. The petitioners, as public officers, participated in preparing and approving the falsified vouchers, which led to the illegal disbursement. Their conspiracy was inferred from their concerted actions to complete the fraudulent scheme.
Regarding the violation of R.A. 3019, Section 3(h), the Court ruled that the petitioners, in their official capacities, had a direct financial interest in the simulated transaction from which they benefited. By fabricating the documents and causing the government to pay for undelivered supplies, they unlawfully enriched themselves. The Court emphasized that the findings of fact by the trial and appellate courts, which found the testimony of the proprietor credible and the documentary evidence conclusive, are binding absent any showing of grave abuse. The petitioners’ denial and alibi could not overcome the positive identification and the paper trail linking them to the crime.