G.R. No. 248317 - Garma y Miguel vs. People

Petitioner Pedrito Garma y Miguel alias “Willy,” jointly charged with his twin brother Reynaldo Garma (deceased), for violation of Article 282 (Grave Threats) of the Revised Penal Code.
Complaint alleged that on February 11, 2010 at about 9:30 AM in Sitio Rissik, Barangay Mabuno, Gattaran, Cagayan, petitioner, moved by personal resentment against Barangay Captain Roseller Ballon, uttered “Patayen mi koman” (“We should have killed him”) to farm helpers of the barangay captain, thereby causing fear.

MTC–Gattaran: Both Garma twins pleaded not guilty; Reynaldo died before trial, and charges against him were dismissed.
Prosecution Witnesses: Barangay Captain Ballon and Marlon P. Timple Jr. testified to the alleged threat.
Defense Testimony: Petitioner narrated prior trespass and assault by Barangay tanod Carmelo Dela Cruz, damage to their fishpond facilities, and alleged harassment motive by the barangay captain to evict them for a water impounding project.

MTC Decision (June 28, 2016): Found petitioner guilty beyond reasonable doubt; imposed medium arresto mayor (2 months + 1 day) and ₱500 fine.
RTC Decision (January 3, 2017): Affirmed MTC judgment.
CA Decision (December 11, 2018; Amended June 18, 2019): Denied appeal, modified penalty to 4 months + 1 day arresto mayor and ₱500 fine, declined application of the Indeterminate Sentence Law.

Whether the Court of Appeals gravely erred in affirming petitioner’s conviction despite alleged deficiencies in proving both the actus reus and mens rea of grave threats.
Whether the exceptional review of factual matters under Rule 45 is warranted because the lower courts overlooked critical facts that, if considered, would change the outcome.