G.R. Nos. 250100-02. March 21, 2022.
People of the Philippines, Plaintiff-Appellee, vs. Rommel C. Arnado, Accused-Appellant.

FACTS

Accused-appellant Rommel C. Arnado, then Mayor of Kauswagan, Lanao del Norte, was charged with three counts of Grave Coercion under Article 286 of the Revised Penal Code, along with Rey A. Camanian and Lauro R. Diputado (members of the Citizen Security Unit) and seven John Does. The Informations alleged that on October 21, October 30, and November 18, 2013, the accused, conspiring and taking advantage of their official positions, willfully prevented complainants Ibra, Osama, and Farhana Sambuat from peaceful living by forcing them through violence, threats, and intimidation to leave the land they claimed to own, and by demolishing their shelters. The charges for Malicious Mischief were dropped. Arnado pleaded not guilty, while Camanian and Diputado remained at large. The Sambuats claimed ownership of the land under OCT No. P-3033 and testified that CSU members, upon Arnado’s command, entered their property, threatened them, and destroyed their shanties on three occasions, despite their protests. They alleged Arnado instructed them to leave during dialogues. The defense, through Atty. Voltaire Rovira, claimed the property was owned by Henry Dy’s group, having purchased it at a tax delinquency sale, and was covered by TCT No. T-4406. Arnado testified he called for dialogues to maintain peace and order due to ownership disputes and potential communal strife, and that the Sambuats agreed to dismantle their tents with CSU assistance, with no demolition occurring. The Sandiganbayan found Arnado guilty, ruling conspiracy existed as the CSU members acted upon his command as Mayor.

ISSUE

Whether the Sandiganbayan erred in finding accused-appellant Rommel C. Arnado guilty beyond reasonable doubt of three counts of Grave Coercion, based on a finding of conspiracy.

RULING

The Supreme Court REVERSED and SET ASIDE the Sandiganbayan’s Decision and Resolution. It ACQUITTED accused-appellant Rommel C. Arnado on reasonable doubt. The Court held that conspiracy must be proven beyond reasonable doubt, the same standard required for the crime itself. The evidence failed to establish conspiracy between Arnado and the CSU members. The Sambuats’ claim that Camanian said “utos sa taas” was insufficient to prove Arnado ordered the coercive acts, as it was hearsay and not corroborated. Arnado’s act of calling for dialogues and referring the matter to the police was a legitimate exercise of his duty as local chief executive to maintain peace and order, given the property dispute and history of communal tensions. His suggestion for the Sambuats to leave pending a court order was a peacekeeping effort, not proof of conspiracy to commit coercion. The presence of CSU members during the dismantling, allegedly upon Arnado’s instruction, was not convincingly established as a means of violence, threat, or intimidation to force the Sambuats out against their will. Since conspiracy was not proven beyond reasonable doubt, Arnado’s criminal liability was not established. The presumption of innocence prevailed.