G.R. No. 165065 - Maderazo vs. People

On October 22, 1997, an Information was filed in Sandiganbayan (First Division) charging Municipal Mayor Melchor G. Maderazo; his nephew, SB Member Victor Maderazo, Jr.; Police Chief Seniforo Perido; and five others with grave coercion for forcibly ejecting Medaria Verutiao from her leased market stall in Caibiran, Biliran, on January 27, 1997.
All accused pleaded not guilty at arraignment.

Verutiao had leased Stall #2 in the Caibiran public market, paid rent, and spent ₱24,267 on construction under Municipal Ordinance No. 2, Series 1984, which entitled her to 50% reimbursement applied to future rentals. Partial reimbursement (₱10,000) was made in 1995; she withheld rent thereafter pending full refund.
On January 13, 1994, a one-year lease was executed (monthly rent ₱400); it expired January 13, 1997. On January 17, 1997, the Mayor ordered Verutiao to vacate within 24 hours for nonpayment (₱2,532 net due). On January 21, 1997, the stall was padlocked; on January 27, 1997, locks were removed, goods inventoried and taken to the police station.

Medaria Verutiao testified as sole witness: she built and operated the stall with municipal authorization, pursued reimbursement from successive treasurers, received the Mayor’s letter-order, was away on January 27, 1997, and learned of the padlocking and inventory only afterward; she alleged political harassment due to opposition affiliation.
Documentary exhibits: lease contract; itemized expenses; Ordinance No. 2 provisions; letters from Mayor and Verutiao’s counsel; inventory report.

Only Victor Maderazo, Jr. testified: as SB member, he executed the Mayor’s order on January 27, 1997 by overseeing the stall’s opening, inventorying goods with Perido and others, and transporting them to the police station; Verutiao was notified but absent.
Other accused opted not to testify; all relied on pre-trial stipulations.

Convicted Maderazo, Perido and Victor Jr. of unjust vexation (Art. 287, RPC, 2nd par.) and imposed ₱200 fine; acquitted the five others for lack of proof of grave coercion.
Held that the Mayor lacked authority to padlock, inventory and seize Verutiao’s goods without resort to administrative or judicial remedies; although no violence or threats occurred, the acts caused annoyance, thus unjust vexation.

Whether petitioners committed unjust vexation under Article 287, RPC, 2nd paragraph.
Whether Mayor Maderazo had authority to padlock a municipal stall and seize its contents without judicial or proper administrative remedy.
Whether failure to prove every fact beyond reasonable doubt mandates acquittal.