FACTS:

The petitioner in this case sought the reversal of his conviction for violation of Section 3 (e) of Republic Act No. 3019, also known as the Anti-Graft and Corrupt Practices Act. The incident in question involved Domingo de Guzman, who at the time was the Officer-in-Charge and Assistant Director of the Bureau of Plant Industry. De Guzman received the sum of P200,000.00 on December 17, 1985, with authority to disburse it for certain official training programs of the Department of Agriculture. However, when required to produce the supporting receipts for the disbursement, he failed or refused to do so. The People presented one witness and several exhibits, including a disbursement voucher, to demonstrate that de Guzman had received the amount but failed to show that it had been lawfully disbursed for the alleged training programs. During the trial, the defense sought to file a demurrer to evidence but was denied permission to do so. Ultimately, the Sandiganbayan found de Guzman guilty of the violation charged and sentenced him to imprisonment, perpetual disqualification from public office, indemnification of the government, and payment of costs. The petitioner claimed that his guilt was not proven beyond reasonable doubt and that the Sandiganbayan should have resolved any doubts in his favor. However, the Court held that there were no doubts in the case. De Guzman admitted receiving the amount but failed to provide any positive evidence or receipts to support his claim that the funds were used for the training programs. The Court concluded that this constituted a violation of Section 3 (e) of the Anti-Graft and Corrupt Practices Act. The petition for reversal was thus denied.

ISSUES:

1. Whether or not the guilt of the petitioner has been proved beyond reasonable doubt.

RULING:

1. The guilt of the petitioner has been proved beyond reasonable doubt. The petitioner admitted receiving the amount of P200,000.00 but failed to provide receipts or any evidence to prove that the amount was lawfully disbursed for the alleged training programs. The lone government witness testified that there were no training programs conducted by the Bureau of Plant Industry during the relevant period. The petitioner's claim that training programs might have occurred without the knowledge of the witness is mere speculation and does not negate the failure to account for the funds. The Sandiganbayan correctly concluded that the petitioner had misappropriated the funds for his personal use or benefit. The evidence presented by the prosecution sufficiently establishes the guilt of the petitioner.

PRINCIPLES:

• The constitutional presumption of innocence may yield to contrary evidence of guilt.

• In criminal prosecutions, every doubt must be resolved in favor of the accused, but this rule does not apply when there is sufficient evidence to establish guilt beyond reasonable doubt.

• The burden of proving the existence of supporting receipts or evidence rests on the petitioner, not the prosecution.

• The mere speculation or conjecture that a certain event might have occurred is not proof of its actual occurrence.