Case Digest (G.R. No. 256116) Core Legal Reasoning Model
Facts:
This case involves a Petition for Certiorari filed by Main T. Mohammad against the Office of the Secretary, Department of Justice, particularly its Secretary, Menardo I. Guevarra. Mohammad was arrested on September 18, 2017, detained, and charged with piracy and two counts of murder, accused as a member of the Abu Sayyaf Group (ASG) responsible for kidnapping and murder. However, the murder charges were dismissed by the Regional Trial Court on April 8, 2019, due to the prosecution's failure to present an identifying witness, effectively acquitting Mohammad. He then filed a claim for compensation under Republic Act No. 7309 (RA 7309), arguing that he was unjustly arrested, accused, and detained for two years for a crime he did not commit. His claim was denied by the Department of Justice Board of Claims for lack of prior conviction, as RA 7309 requires a prior conviction followed by a subsequent acquittal for compensation eligibility. The Secretary of Justice affirmed the de
... Case Digest (G.R. No. 256116) Expanded Legal Reasoning Model
Facts:
- Arrest and Charges
- Petitioner Main T. Mohammad was arrested on September 18, 2017.
- He was charged with piracy and two counts of murder.
- Mohammad was identified as a member of the Abu Sayyaf Group (ASG) linked to kidnapping and murder.
- Trial and Acquittal
- On April 8, 2019, the murder charges were dismissed because the prosecution could not present a witness to identify Mohammad as the accused.
- Mohammad was acquitted by the Regional Trial Court (RTC) on these grounds.
- Claim for Compensation
- Mohammad filed a claim for compensation under Republic Act No. 7309 before the Department of Justice Board of Claims, contending he was "unjustly arrested, accused, and detained" for two years for a crime he did not commit.
- He argued that Section 3(a) of RA 7309 covers persons unjustly accused, convicted, and imprisoned but subsequently acquitted.
- Mohammad contended the conjunctive "and" in the law should be construed disjunctively "or" to avoid injustice.
- Board and Secretary Decisions
- The Board denied his claim by Resolution No. 2020-28 dated November 6, 2020, citing lack of prior conviction and that release by acquittal must be on appeal.
- Mohammad appealed to the Office of the Secretary of Justice.
- The Secretary denied the appeal on February 1, 2021, affirming the Board's decision.
- The Secretary held that Section 3(a) unambiguously requires unjust accusation, conviction, imprisonment, and release by judgment of acquittal on appeal.
- The Secretary ruled that arbitrary classification claims must fail absent proof of arbitrariness.
- Petition for Certiorari
- Mohammad filed a petition before the Supreme Court, arguing grave abuse of discretion by the Secretary.
- He challenged the restrictive interpretation of "judgment of acquittal" and the constitutionality of Section 3(a) for violating equal protection.
- Supporting Comments and Counterpoints
- The Secretary, via the Solicitor General, maintained the denial was lawful and based on the clear language of RA 7309.
- The Secretary emphasized all elements must concur to sustain a claim, and no prior conviction existed.
Issues:
- Whether the Secretary of Justice committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying petitioner Mohammad's appeal for compensation under Republic Act No. 7309.
- Whether the interpretation of Section 3(a) of RA 7309 requiring prior conviction and subsequent acquittal violates the constitutional equal protection clause.
- Whether the conjunctive "and" in Section 3(a) should be construed disjunctively to aid persons like Mohammad who were unjustly accused but never convicted.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)