GR 28759; (September, 1928) (Digest)

G.R. No. 28759, September 19, 1928
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. MARGARITO MEDIAVILLA, defendant-appellant.

DOCTRINE:
1. A prosecuting attorney is not disqualified from handling two related criminal cases merely because the accused in one case are the offended parties in the other, and vice versa. The prosecuting attorney represents the People of the Philippines, the primary offended party in all crimes, and not the private individuals involved.
2. The act of defending a stranger from an unlawful aggression is a justifying circumstance under the Revised Penal Code, provided it is done without revenge, resentment, or other unlawful motive.

FACTS

Margarito Mediavilla was charged and convicted by the Court of First Instance of Iloilo for the crime of less serious physical injuries against Clemente Babiera. He was sentenced to two months and one day of *arresto mayor*.

The case arose from a violent incident involving two groups. In a related case (G.R. No. 28871, *People vs. Babiera*), it was established that Clemente Babiera was the unlawful aggressor against Severino Haro. Mediavilla was implicated for wounding Babiera at the base of his little finger during this incident.

Mediavilla appealed, raising two main issues: (1) that the prosecuting attorney was disqualified for allegedly representing conflicting interests by filing separate cases where the accused in one were the complainants in the other, and (2) that the evidence did not prove he was the one who inflicted the injury on Babiera.

ISSUES:
1. Did the prosecuting attorney commit a conflict of interest by prosecuting both cases, thereby warranting the dismissal of the case against Mediavilla?
2. Was Mediavilla’s guilt for inflicting less serious physical injuries on Clemente Babiera proven beyond a reasonable doubt?

RULING

The Supreme Court REVERSED the judgment of the trial court and ACQUITTED Margarito Mediavilla.

1. On the alleged conflict of interest of the prosecuting attorney: The Court held there was no disqualification. The prosecuting attorney represents the People of the Philippines, the sovereign entity offended by the violation of its laws. He does not represent the private offended parties. Therefore, there is no ethical breach in prosecuting two related cases where the roles of accused and complainant are interchanged between the private individuals involved. The duty of the fiscal is to pursue the interest of the state in both instances.

2. On the sufficiency of evidence proving guilt: The Court acquitted Mediavilla based on reasonable doubt. The ruling in the related case (*People vs. Babiera*) conclusively established that Clemente Babiera was the unlawful aggressor against Severino Haro. Given this context, even if Mediavilla were present and inflicted the wound on Babiera, his act would be justified as defense of a stranger, absent proof of an unlawful motive like revenge. Furthermore, the evidence showed that Mediavilla was in town at the time of the incident, which occurred in a distant location, making his physical presence at the scene doubtful. The minor wound on Babiera’s hand, by itself, does not disprove that he was the aggressor. Consequently, the prosecution failed to prove Mediavilla’s guilt beyond a reasonable doubt.