Customs official’s conviction reversed, set aside
The Sandiganbayan has set aside the Manila Regional Trial Court’s appeal against a former Bureau of Customs officer, who has been found guilty of failing to declare her business interests in her statement of assets, liabilities, and net worth in 2010.
The anti-graft court ruled in a 19-page decision that the Manila RTC’s decision convicting Delia Morala, a former Customs Operations Officer V of the BoC, of the charge of falsification under Article 171, paragraph 4 of the Revised Penal Code, was “reversed” and “set aside” due to the prosecution’s failure to prove her guilt beyond a reasonable doubt.
“The Decision dated 19 January 2022 of the Regional Trial Court of Manila, Branch 21, National Capital Judicial Region convicting the accused-appellant in Criminal Case No. 1800791 is REVERSED and SET ASIDE,” the decision read.
The case stemmed after the RTC found that Morala had made an “untruthful statement” in her SALN by failing to state that her husband was an incorporator and stockholder of a real estate firm.
According to the Manila RTC’s decision, Morala committed the crime of falsification by a public officer when she answered “No” to the question: “Do you have any interests and other financial connections, including those of your spouse and unmarried children under the age of 18 living in your household?” “in her 2010 SALN, when her husband Mariano Morala was a stockholder and incorporator of Moravilla Real Estate Corp.
The former BoC official, in her defense, claimed she never knew that the company existed and that her husband was part of it as they were already living separately at the time.
Her conviction was based on several criminal cases filed against her in 2017 by the Office of the Ombudsman, which also stemmed from a complaint from the Revenue Integrity Protection Service of the Department of Finance.
Morala was ordered to pay a P5,000 fine by the Manila RTC and sentenced to an indeterminate jail term of two years, four months, and one day (prison correctional medium) as the minimum penalty, to 8 years and one day (prison mayor medium) as the maximum penalty.
However, the Sandiganbayan ruled: “In parting, the Court echoes the closing statement of the Ramirez case in that herein accused-appellant Morala may have committed a mistake, or that she was truly dishonest, but such mistake or dishonesty was not uniquely and particularly afforded to her by her office or the position she occupied.”
It also added: “She may be held to account for any wrongdoing that she might have committed, but in this instance, insofar as the liability under Article 171(4) is concerned, the constitutional presumption of her innocence in her favor shall be upheld.”
The decision was promulgated on 11 November 2022, penned by Associate Justice chairperson Rafael Lagos and concurred by Associate Justices Maria Theresa Mendoza-Arcega and Maryann Corpus-Mañalac.