Case Summary (G.R. No. 127440)
Background and Proceedings
The complaint was filed with the Metropolitan Trial Court (MeTC) in Parañaque City for malicious mischief and trespass. Bolbes alleged that petitioners and co-accused, upon the order of Teofilo and Olive Grana, entered and damaged his property without consent by destroying the iron fence, removing the cement foundation, and digging into the apartment’s foundation, risking the structure’s integrity. The accused pleaded not guilty (except for Ricky Dimaganti who remained at large), and the matter was unsuccessfully referred to mediation before trial.
Trial Court Findings (MeTC and RTC)
The MeTC found all accused guilty beyond reasonable doubt of malicious mischief under Criminal Case No. 03-2756, and Teddy Grana and Gil Valdes guilty of other forms of trespass under Criminal Case No. 03-2757. The court held that the elements of malicious mischief—deliberate damage to property not constituting arson or other destruction crimes—were met. It rejected any justification by petitioners, stressing they acted out of spite and malice rather than rightful ownership claims. Sentences included imprisonment of four months and damages amounting to ₱7,500 plus attorney’s fees and other costs.
On appeal, the Regional Trial Court (RTC) affirmed the MeTC’s rulings, emphasizing that even assuming disputed ownership, petitioners could not take the law into their own hands by damaging complainant’s improvements. The RTC highlighted the established conspiracy and rejected the defense’s claim that the acts were meant for protection or lacked malice.
Court of Appeals Decision
The Court of Appeals (CA) partially granted petitioners' appeal by affirming the malicious mischief conviction but acquitted Teddy Grana and Gil Valdes of other forms of trespass, citing failure of the prosecution to prove that the property was uninhabited at the time of entry—a necessary element for trespass. The CA emphasized that assumptions are insufficient as proof and that the prosecution did not discharge its burden of proving this essential fact.
Petitioners’ Arguments in the Petition for Review
Petitioners Teddy and Teofilo Grana argued that not all elements of malicious mischief were established beyond reasonable doubt, denying bad faith or malice and asserting that their acts were not intended to cause damage but to remove an allegedly illegal fence constructed by Bolbes.
Supreme Court's Analysis and Ruling
The Supreme Court held that the petitioners’ claims essentially required a re-evaluation of factual findings and evidence—matters reserved for the trial courts, not the Court, absent manifest error or grave abuse of discretion. It underscored the finality and binding effect of the RTC and CA’s affirmed factual findings, given their opportunity to observe demeanor and credibility of witnesses.
Applying Article 327 of the Revised Penal Code under the 1987 Philippine Constitution, the Court confirmed the following elements of malicious mischief were proven: (1) deliberate damage to another’s property, (2) the damage did not constitute arson or other crimes involving destruction, and (3) the act was done maliciously and without legal justification. The Court found that the respondents unlawfully destroyed Bolbes’s property improvements not for rightful ownership defense but maliciously to vent anger and revenge.
Penalty Modification Under Republic Act No. 10951
The Court modified the original penalty of four months imprisonment, reducing it to arresto menor (imprisonment of one to thirty days) with reference to Republic Act No. 10951, wh
...continue readingCase Syllabus (G.R. No. 127440)
Background and Procedural History
- This Petition for Review on Certiorari challenges the February 21, 2012 Decision and June 6, 2012 Resolution of the Court of Appeals (CA), which partially reversed the May 16, 2011 Decision of the Regional Trial Court (RTC), Branch 195, Parañaque City.
- The RTC Decision had affirmed the August 10, 2010 Joint Decision of the Metropolitan Trial Court (MeTC), Branch 77, Parañaque City in Criminal Cases Nos. 03-2756 and 03-2757.
- Criminal Case No. 03-2756 involved a charge of malicious mischief filed by complainant Freddie Bolbes against Teddy Grana, Gil Valdes, Ricky Dimaganti, Olive Grana, and Teofilo Grana.
- Criminal Case No. 03-2757 charged Teddy Grana, Gil Valdes, and Ricky Dimaganti with Other Forms of Trespass.
- Accused pleaded not guilty except for Ricky Dimaganti who remained at large.
- Attempts at amicable settlement through the Philippine Mediation Office were unsuccessful.
Facts of the Case
- Complainant Freddie Bolbes and the accused were neighbors in Bernabe Subdivision, Parañaque City.
- Bolbes claimed ownership of the subject property, having purchased it from the Home Insurance and Guaranty Corporation (HIGC) for P554,400.00 via a Contract to Sell dated February 28, 2002.
- Bolbes started occupying the property in 1989, before his application with HIGC.
- Bolbes testified that on July 6, 2003, petitioners Teddy Grana and accused Gil and Ricky, under orders from Teofilo and Olive Grana and without Bolbes’s consent, unlawfully entered the property.
- They destroyed an iron fence, removed the cement foundation, and dug up a portion of Bolbes’s apartment foundation, risking damage from heavy rains.
- The intruding parties stopped their actions only upon arrival of Barangay Tanods.
- Barangay Tanod Andres Bonifacio testified to receiving Bolbes’s complaint and attempted to stop the accused from further acts.
Defense’s Version
- Only Teofilo Grana testified for the defense.
- He claimed to have bought the property from Clarito Baldeo, who had purchased it from Alexandra Bernabe, supported by a contract of lease with option to purchase.
- Teofilo admitted digging a portion of the lot intending to build a perimeter fence for mutual protection but claimed Bolbes halted construction.
- He referred the dispute to the barangay for settlement, which Bolbes agreed to.
- He asserted ownership and stated he demolished the fence because Bolbes built it without his consent.
Trial Court Findings (MeTC)
- The MeTC found all accused guilty beyond reasonable doubt for malicious mischief (Crim. Case No. 03-2756).
- It convicted Teddy Grana and Gil Valdes for Other Forms of Trespass (Crim. Case No. 03-2757).
- The Court ruled that all elements of the two crimes were satisfied.
- The MeTC sentenced the accused to imprisonment (four months for malicious mischief) and ordered payment of damages and costs.
- Ricky Dimaganti's case was archived,