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

Case Summary (G.R. No. 248317)

Facts as Alleged by Prosecution

On February 11, 2010, three farm workers for Barangay Captain Ballon were loading a water pump in Barangay Mabuno when they encountered the Garma twins chasing suspected fish thieves. Upon learning that Ballon was not present, petitioner allegedly said in Ilocano, “Patayen mi koman” (“We should have killed him”). The workers reported the remark to Ballon, who feared for his life and filed a grave-threats complaint under Article 282, paragraph 2, RPC.

Defense Version of Events

Petitioner testified that on February 9, he was assaulted by barangay tanod Carmelo Dela Cruz during a boundary dispute. The next day he and his brother discovered trespassers in their fishpond and went to report the incident to the PNP, not Ballon. He denied ever threatening Ballon and characterized the complaint as harassment intended to facilitate the water impounding project that would affect his fishpond.

Lower Courts’ Rulings

The MTC found petitioner guilty beyond reasonable doubt and imposed medium arresto mayor and a ₱500 fine. The RTC affirmed. The CA denied petitioner’s appeal but modified the penalty under the Indeterminate Sentence Law, later removing ISL application in its Amended Decision of June 18, 2019.

Issue on Review

Whether the CA erred in affirming conviction when petitioner’s guilt for grave threats was not proven beyond reasonable doubt, particularly as to actus reus and mens rea.

Legal Framework: Grave Threats under RPC

Article 282 defines two forms of grave threats:

With condition—penalty one degree lower than that for the threatened crime.
Without condition—arresto mayor and fine up to ₱500.

Elements to convict under paragraph 2 (no condition):

Actus reus: utterance of a threat against person, honor, or property amounting to a crime
Mens rea: intent that the utterance intimidate or be taken seriously

Actus Reus Analysis

The Court found the sole testimony of Timple, Jr. regarding the remark implausible. It was unreasonable that petitioner and his brother, in active pursuit of trespassers, would pause to ask for Ballon’s whereabouts and spontaneously utter a threat against an absent person. The absence of corroboration from the other two witnesses, Duca and Gammuac, rendered the prosecution’s evidence insufficient to establish actus reus beyond reasonable doubt.

Mens Rea Analysis

Assuming arguendo the utterance occurred, the prosecution failed to prove that petitioner int

Case Syllabus (G.R. No. 248317)

Procedural Posture

Petition for Review on Certiorari under Rule 45 filed by Pedrito Garma y Miguel alias “Willy” challenging the Court of Appeals’ Amended Decision of June 18, 2019 in CA-G.R. CR No. 39545.
The CA had affirmed the conviction for grave threats but modified the penalty to four months and one day imprisonment and a fine of ₱500, without applying the Indeterminate Sentence Law.
Prior rulings: • Municipal Trial Court (Gattaran, Cagayan) – Convicted the petitioner of grave threats; sentenced to medium period of arresto mayor (2 months + 1 day) and a ₱500 fine.
• Regional Trial Court (Aparri, Cagayan Branch 6) – Affirmed the MTC conviction.
• Court of Appeals – Denied petitioner’s appeal, modified penalty, denied Indeterminate Sentence Law application.
Relief sought: Acquittal on ground that prosecution failed to establish guilt beyond reasonable doubt.

Facts

On February 9, 2010, barangay tanod Carmelo Dela Cruz and companions entered petitioner’s fenced property demanding proof of boundaries; petitioner showed a survey document which they called “useless,” then assaulted him and brought him to the hospital.
On February 10, 2010, petitioner and his twin brother Reynaldo discovered illegal fishers in their fishpond; they found damage to the water impounding project’s valve, shafting, fence and posts.
On February 11, 2010 at around 9:30 AM in Sitio Rissik, Barangay Mabuno, petitioner and Reynaldo chased the trespassers but paused upon encountering three farm workers (Timple Jr., Duca, Gammuac) of Barangay Captain Roseller Ballon.
Upon learning Ballon was not present, petitioner allegedly said in Ilocano “Patayen mi koman” (“We should have killed him”) and then resumed the chase of the fishers.
The three farm workers reported the remark to Barangay Captain Ballon who, fearing for his life, filed a complaint for grave threats against the Garma twins on February 15, 2010.

Prosecution’s Version

Witnesses: Barangay Captain Ballon; Marlon P. Timple, Jr.; Ricky Duca; Jovanis Gammuac.
Key points: • The twins opposed Ballon’s proposed water impounding project affecting their fishpond.
• While loading a water pump, the three farmers saw petitio