FACTS:

On October 22, 1997, an Information was filed before the Sandiganbayan charging several individuals, including Municipal Mayor Melchor G. Maderazo, his nephew Victor Maderazo Jr., and Seniforo Perido, Caibiran Police Station Chief, with grave coercion. The accused were accused of forcibly ejecting Medaria Verutiao from the market stall she was occupying and leasing from the Municipality of Caibiran. Verutiao had not paid rent since 1993 because she had not been fully reimbursed for the construction of the stall. On January 17, 1997, Mayor Maderazo sent a letter-order to Verutiao to vacate the stall within 24 hours. The mayor padlocked the stall on January 21, 1997, but the locks were opened on his authority on January 27, 1997.

During the trial, it was established that Verutiao was not present at the market stall during the padlocking incident, as she was in her farm about 4 to 5 kilometers away. Victor Maderazo testified that he was present at the market stall when the inventory of goods was conducted upon the request of Mayor Maderazo. Verutiao was informed beforehand but failed to attend. The goods were brought to the police station for safekeeping.

The Sandiganbayan convicted Melchor Maderazo, Seniforo Perido, and Victor Maderazo, Jr. of unjust vexation, ruling that Melchor Maderazo exceeded his authority in padlocking the market stall and seizing the goods. The court held that while the accused cannot be convicted of grave coercion as there was no use of violence or threats, they could still be held criminally liable for unjust vexation as their actions caused annoyance and vexation. The court imposed a fine of Two Hundred Pesos (P200.00) on the convicted accused. The acquitted accused had their cash bond returned and the hold departure orders against them were set aside.

The convicted accused, now petitioners, filed a petition arguing that they should not be criminally liable for unjust vexation as Verutiao was not present during the padlocking and inventory of goods. They claimed that the prosecution failed to prove their guilt beyond reasonable doubt.

ISSUES:

1. Whether the petitioners are criminally liable for unjust vexation.

2. Whether petitioner Melchor Maderazo can be held guilty of unjust vexation for the overt acts of his co-petitioners.

3. Whether the prosecution was able to prove beyond reasonable doubt the guilt of the petitioners for unjust vexation.

4. Whether the petitioners had the right to oust the respondent from her stall without judicial intervention.

5. Whether the respondent's stall can be considered vacant and disposed of under the municipality's ordinance.

6. Whether the petitioner mayor should have filed an action for eviction instead of taking the law into his own hands.

RULING:

1. The petitioners are not criminally liable for unjust vexation. The Court found that Verutiao was not prevented from doing anything not prohibited by law, and she was not transacting business at the time. Furthermore, only petitioner Mayor Maderazo was involved in the padlocking of the stall, not the other petitioners. Therefore, the charge of unjust vexation does not apply to all the petitioners.

2. Petitioner Melchor Maderazo cannot be held guilty of unjust vexation for the overt acts of his co-petitioners. The Court ruled that since Melchor Maderazo was not at the stall when the incident happened, he cannot be held responsible for the actions of his co-petitioners on that day.

3. The court agrees with the contention of the respondents that the prosecution was able to prove beyond reasonable doubt the guilt of the petitioners for unjust vexation. Article 287 of the Revised Penal Code covers the crime of light coercion and other coercions or unjust vexations. The second paragraph of this article states that unjust vexations include human conduct which, although not causing physical or material harm, could unjustifiably annoy or vex an innocent person. In this case, the court found that the overt acts of the petitioners, namely ordering the padlocking, inventory, and transportation of the goods inside the market stall, annoyed, irritated, and caused embarrassment to the complainant. It was also found that the participation of the petitioners went beyond being witnesses as they admitted to opening the stall and accounting for its contents. Good faith is a defense against the charge of unjust vexation, but in this case, the court did not find that the petitioners acted in good faith. Therefore, the court ruled that the petitioners are guilty of unjust vexation.

4. The petitioners did not have the right to evict the respondent from her stall without judicial intervention. The petitioner mayor cannot take the law into his own hands and deprive the respondent of her possession and means of livelihood.

5. While the respondent's lease contract with the municipality had expired and she failed to pay the rent, the stall cannot be considered vacant and disposed of under the municipality's ordinance without first filing an action for eviction.

6. The petitioner mayor should have filed an action for eviction instead of taking matters into his own hands. He cannot invade the property and oust the lessee who is entitled to actual possession, and burden the lessee with filing an action to assert their property right.

PRINCIPLES:

• A person cannot be criminally liable for unjust vexation if the complainant was not prevented from doing something not prohibited by law.

• Each accused should be individually liable for his/her actions and cannot be held responsible for the acts of his/her co-accused, unless proven otherwise.

• Forcible entry and unlawful detainer are summary proceedings designed to protect actual possession and maintain the status quo until the question of ownership is resolved by a court of competent jurisdiction.

• Public officers must act within the confines of the law and not resort to criminal acts in the enforcement of laws and ordinances.

• The burden of filing an action for eviction rests on the party seeking eviction, not the party in possession.