GR L 54645; (December, 1986) (Digest)
G.R. Nos. L-54645-76 December 18, 1986
REYNALDO R. BAYOT, petitioner, vs. THE SANDIGANBAYAN AND PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Reynaldo R. Bayot, a former Auditor of the Ministry of Education and Culture (MEC), was charged and convicted by the Sandiganbayan, along with several others including Lorenzo Ga. Cesar, for the complex crime of estafa through falsification of public documents. The charges stemmed from the alleged fraudulent encashment of numerous TCAA checks totaling over P12 million, which were purportedly falsified to appear as payments to fictitious suppliers. The prosecution’s theory was that the accused, taking advantage of their official positions, conspired to prepare, sign, and encash these checks. Bayot’s specific alleged participation was his purported signature on the checks as a signatory.
The evidence presented by the prosecution against Bayot was identical to the evidence previously presented against his co-accused, Lorenzo Ga. Cesar. In a prior en banc decision (G.R. Nos. L-54719-50, January 17, 1985), the Supreme Court acquitted Cesar, ruling that the evidence was “woefully inadequate” and “too conjectural and presumptive to establish personal culpability.” Following Cesar’s acquittal, Bayot filed the instant petition for review, seeking a similar reversal of his conviction based on the same insufficient evidence.
ISSUE
Whether the evidence presented by the prosecution is sufficient to prove the guilt of petitioner Reynaldo R. Bayot beyond reasonable doubt for the crime of estafa through falsification of public documents.
RULING
No. The Supreme Court granted the petition, reversed the Sandiganbayan’s decision, and acquitted Reynaldo R. Bayot. The Court’s ruling was anchored on the principle of consistency and the constitutional presumption of innocence. Since the Court had already definitively ruled in the earlier Cesar case that the identical evidence was insufficient to prove guilt beyond reasonable doubt, it must extend the same legal consequence to Bayot. To hold otherwise would be a denial of equal justice.
The Court elaborated that the evidence failed to directly and convincingly link Bayot to the forgery and fraud. The Sandiganbayan’s own findings indicated that the blank checks were requisitioned and kept by another accused, and that the typing and encashment were orchestrated by the principals (Amado Fernandez and Josephine Estanislao) who had fled. Applying the legal presumption that one who uses a forged document is presumed to be the forger, the logical authors were those who presented and encashed the checks, not Bayot. There was no evidence that Bayot profited from the scheme or conspired with the other accused before, during, or after the commission of the crime. His alleged signatures on the checks were sufficiently indicated to be forgeries. Given the complete absence of reliable, non-conjectural evidence to sustain a conviction, and in light of the prior acquittal of his co-accused based on the same proof, acquittal on the ground of reasonable doubt is imperative.