FACTS:

In two separate cases, criminal complaints for qualified theft were filed against two individuals, Sally Go-Bangayan and Victoria Martinez. In both cases, the accused allegedly endorsed and deposited checks meant for their respective employers into their personal accounts in Security Bank. Security Bank, being the victim, sought to present evidence of the stolen checks and the testimony of its representative, Marasigan, during the criminal proceedings.

In Go-Bangayan's case, the trial court denied her motion to quash the subpoena duces tecum / ad testificandum against Security Bank and another bank, which were requested by the prosecution. The court also denied her subsequent motion to suppress the testimony and documents related to her personal bank account. Go-Bangayan appealed the denial to the Court of Appeals.

In Martinez's case, the trial court ruled that Marasigan's testimony and the evidence related to her bank account were inadmissible as evidence, citing the absolute confidentiality of bank deposits under Republic Act No. 1405. Security Bank appealed the ruling to the Court of Appeals, which granted the petition and ordered the stricken testimony to be admitted as evidence. Martinez's motion for reconsideration was denied, and Security Bank filed a petition for review with the Supreme Court.

The main issue to be resolved in both cases was the admissibility and relevance of Marasigan's testimony and the evidence related to the accused's bank accounts. The Supreme Court emphasized the need for the evidence to establish the constituent acts of theft with unwavering certainty and pass the test of relevancy and competency under the Rules of Court. Ultimately, the Court ruled that the evidence sought to be suppressed lacked a direct relation to the fact in issue and did not overcome the presumption of guiltlessness.

ISSUES:

1. Whether the testimony of Marasigan and the documentary evidence related to the respondent's Security Bank account are relevant to the case.

2. Whether the admission of Marasigan's testimony and the corresponding documents violate the confidentiality of bank deposits under Republic Act (R.A.) No. 1405.

RULING:

1. Relevance The testimony of Marasigan and the related documentary evidence are irrelevant to the case because the criminal information specifically alleges the theft of cash, not checks. The presentation of evidence regarding checks does not directly relate to the theft of cash alleged in the information.

2. Confidentiality (R.A. No. 1405) The admission of Marasigan's testimony and the accompanying documents constitutes an impermissible inquiry into a bank deposit account, which is protected by the absolute confidentiality rule under R.A. No. 1405. The subject matter of the trial is the alleged stolen cash, not the bank account or the checks, and thus does not fall within any exceptions provided by the law.

PRINCIPLES:

1. Relevance of Evidence Evidence must have a direct relation to the fact in issue to be deemed relevant. In this case, disjunct between theft of cash and evidence related to checks renders the latter inadmissible.

2. Bank Deposit Confidentiality Under R.A. No. 1405, all bank deposits are considered absolutely confidential and may only be examined or inquired into under specific exceptions, none of which apply in this case.

3. Subject Matter in Litigation Exception To invoke the "subject matter in litigation" exception to bank confidentiality, the money deposited must itself be the object of the action, not simply related to the case.

4. Standard of Proof in Criminal Prosecution The elements of the offense must be proven with moral certainty; in theft cases, this includes the unlawful taking of the specified stolen property. Proper alignment of allegations and evidence is imperative for the prosecution.

5. Interpretation of Statutory Confidentiality When there is ambiguity in interpreting confidentiality provisions, doubts must generally be resolved in favor of maintaining the confidentiality of bank deposits.