Scribd
Upload
76 views1 page

Bautista V Sarmiento

Dr. Leticia C. Yap filed an estafa case against Dr. Fe Bautista, Milagros Corpus and Teresita Vergere that was heard by Judge Malcolm G. Sarmiento. The accused filed a motion to dismiss for insufficiency of evidence, which was denied, and they were later found guilty. The issue was whether conviction requires proof beyond reasonable doubt. The ruling found that establishing a prima facie case shifts the burden of evidence, not the burden of proof, to the accused to present evidence countering the prosecution's case. A prima facie case does not need to be countered by a preponderance of evidence or greater weight, but merely evidence equalizing the weight of

Uploaded by

leeashlee
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
76 views1 page

Bautista V Sarmiento

Dr. Leticia C. Yap filed an estafa case against Dr. Fe Bautista, Milagros Corpus and Teresita Vergere that was heard by Judge Malcolm G. Sarmiento. The accused filed a motion to dismiss for insufficiency of evidence, which was denied, and they were later found guilty. The issue was whether conviction requires proof beyond reasonable doubt. The ruling found that establishing a prima facie case shifts the burden of evidence, not the burden of proof, to the accused to present evidence countering the prosecution's case. A prima facie case does not need to be countered by a preponderance of evidence or greater weight, but merely evidence equalizing the weight of

Uploaded by

leeashlee
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 1

Bautista v.

Sarmiento
138 SCRA 587
Facts:
Complainant Dr. Leticia C. Yap filed a case of estafa against Dr. Fe Bautista,
Milagros Corpus and Teresita Vergere. The case was heard before the sala of Judge
Malcolm G. Sarmiento. The accused filed a motion to dismiss on the ground of
insufficiency of evidence against them but it was denied. They were later found
guilty for said crime.
Issue:
Whether or not conviction can be had in a criminal case only upon proof
beyond reasonable doubt and not on a mere prima facie case.
Ruling:
There is no denying that in a criminal case, unless the guilt of the accused is
established by proof beyond reasonable doubt, he is entitled to an acquittal. But
when the trial court denied petitioners' motion to dismiss by way of demurrer to
evidence on the ground that the prosecution had established a prima facie case
against them, they assumed a definite burden. It became incumbent upon
petitioners to adduce evidence to meet and nullify, if not overthrow, the prima facie
case against them. This is due to the shift in the burden of evidence, and not of the
burden of proof as petitioners would seem to believe.

When a prima facie case is established by the prosecution in a criminal case,


as in the case at bar, the burden of proof does not shift to the defense. It remains
throughout the trial with the party upon whom it is imposedthe prosecution. It is
the burden of evidence which shifts from party to party depending upon the
exigencies of the case in the course of the trial. This burden of going forward with
the evidence is met by evidence which balances that introduced by the prosecution.
Then the burden shifts back.

A prima facie case need not be countered by a preponderance of evidence or


by evidence of greater weight. Defendant's evidence which equalizes the weight of
plaintiff's evidence or puts the case in equipoise is sufficient. As a result, plaintiff
will have to go forward with the proof. Should it happen that at the trial the weight
of evidence is equally balanced or at equilibrium and presumptions operate against
plaintiff who has the burden of proof, he cannot prevail.

You might also like