GR 165065; (September, 2006) (Digest)
G.R. No. 165065 ; September 26, 2006
MELCHOR G. MADERAZO, SENIFORO PERIDO, and VICTOR MADERAZO, JR., petitioners, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
Petitioners, Municipal Mayor Melchor Maderazo, Sangguniang Bayan member Victor Maderazo, Jr., and Police Chief Seniforo Perido, were charged with grave coercion. The prosecution alleged that on January 27, 1997, they forcibly ejected Medaria Verutiao from her leased market stall in Caibiran, Biliran. Verutiao had constructed the stall with her own funds under a municipal ordinance allowing reimbursement through rental credits. While she had unpaid rentals, she claimed the municipality’s outstanding reimbursement debt offset her obligations. After Verutiao failed to comply with the Mayor’s 24-hour vacate order, the stall was padlocked on January 21, 1997. On January 27, the padlocks were opened on the Mayor’s authority, the stall’s contents were inventoried by Victor Maderazo, and the goods were transferred to the police station under Perido’s custody. Verutiao was not physically present during this inventory and removal.
ISSUE
Whether the petitioners are guilty of unjust vexation, a lesser offense included in the charge of grave coercion.
RULING
Yes, the petitioners are guilty of unjust vexation. The Sandiganbayan correctly convicted them of this lesser included offense. For grave coercion under Article 286 of the Revised Penal Code to exist, the element of violence or intimidation must be proven. The records show that the acts of padlocking the stall, opening it, inventorying the contents, and transferring the goods to the police station were done in the absence of Verutiao. Consequently, there was no direct proof that these acts were accomplished through violence or intimidation exerted upon her person at that moment. The Court emphasized that coercion must be shown to have been employed to compel the victim against her will.
However, the acts committed still constituted unjust vexation, a form of light coercion defined as any human conduct that, without causing any other specific crime, annoys, irritates, or distresses a person. The petitioners’ actions, undertaken under color of official authority, caused annoyance and distress to Verutiao by dispossessing her of the stall and her goods. The Mayor’s act of padlocking and ordering the stall’s clearing, executed with the assistance of his co-petitioners, exceeded the bounds of a mere contractual dispute over lease obligations and constituted a vexatious use of power. Thus, while the prosecution failed to prove all elements of grave coercion, it sufficiently established the petitioners’ guilt for the lesser offense of unjust vexation.