**Felicito Basbacio vs. Office of the Secretary Department of Justice, Franklin Drilon in His Capacity as Secretary of Justice**
### Facts:
On the night of June 26, 1988, in Palo, Calanuga, Rapu-Rapu, Albay, Felicito Basbacio and his son-in-law, Wilfredo Balderrama, were implicated in the killing of Federico Boyon and the wounding of his wife, Florida, and son, Tirso. This incident stemmed from an ongoing land dispute between Basbacio and the Boyons. Both defendants were charged with frustrated murder. While both pleaded their innocence, the trial court convicted them based on the evidence presented, which included the testimony of a relative identifying Basbacio as Balderrama’s companion at the scene. The defendants were incarcerated after their bail was revoked pending their appeal.
Basbacio’s son-in-law failed to proceed with his appeal; however, Basbacio continued and was subsequently acquitted by the Court of Appeals on June 22, 1992. The appellate court found insufficient proof of conspiracy between Basbacio and Balderrama, given Basbacio’s passive presence at the crime scene.
Post-acquittal, Basbacio sought compensation under Rep. Act No. 7309 for unjust accusation, conviction, and subsequent imprisonment. The Department of Justice Board of Claims denied his request, arguing his acquittal did not equate to innocence, and he was “probably guilty” due to existing motives and relations to the deceased. The Secretary of Justice affirmed this decision, leading Basbacio to appeal to the Supreme Court via a petition for review on certiorari, which the Court treated as a special civil action for certiorari under Rule 65 due to the significance of the legal questions involved.
### Issues:
1. **Interpretation of “Unjustly Accused, Convicted, and Imprisoned”** – Whether the term requires a claimant under Rep. Act No. 7309 to be found innocent on appeal, or if proof of acquittal is sufficient for compensation.
2. **Evaluation of Statistical Claims under Rep. Act No. 7309** – Whether the Board of Claims and the Secretary of Justice committed a grave abuse of discretion in denying Basbacio’s claim for compensation based on the circumstantial doubt surrounding his acquittal.
### Court’s Decision:
1. **Interpretation of Rep. Act No. 7309, Sec. 3(a)**:
– The Supreme Court dismissed the notion that acquittal alone warrants compensation, stressing that Rep. Act No. 7309 demands proof of unjust accusation, conviction, and imprisonment. They clarified that acquittal does not necessarily translate to proven innocence; it may result from reasonable doubt. Therefore, each case must demonstrate an unjust prosecution from the onset, except then leading to wrongful conviction and imprisonment.
2. **Legitimacy of Board and Secretary’s Decision**:
– The Supreme Court upheld the decisions of the Board of Claims and the Secretary of Justice, finding no grave abuse of discretion. The circumstances surrounding Basbacio’s involvement—his relationship to the convicted party and existing motive—provided a reasonable basis for their assessment, negating an illegitimate accusation or conviction.
**WHEREFORE, the petition is DISMISSED.**
### Doctrine:
1. **Presumption of Innocence vs. Proof of Innocence**:
– The presumption of innocence serves primarily to assign the burden of proof to the prosecution but does not equate to actual proof of innocence.
2. **Definition of ‘Unjust Conviction’**:
– The term “unjust conviction” involves the deliberate miscarriage of justice or gross negligence/malice, akin to “knowingly rendering an unjust judgment” under Article 204 of the Revised Penal Code.
### Class Notes:
– **Key Concepts**:
– **Rep. Act No. 7309**: Provides compensation claims for unjustly accused, convicted, and imprisoned persons.
– **Reasonable Doubt vs. Innocence**: Proof beyond reasonable doubt is required for conviction in criminal cases, but acquittal on this ground does not establish compensation eligibility without showing an unjust prosecution process.
– **Statutory Provisions**:
– **Rep. Act No. 7309, Sec. 3(a)**: Compensation for unjustly accused, convicted, and imprisoned individuals.
– **Art. 29, Civil Code**: Allows civil actions based on the same acts giving rise to criminal cases when acquittal is due to lack of proof beyond reasonable doubt.
### Historical Background:
This case emerges within the context of refining judicial interpretation standards post-Marcos era, emphasizing judicial propriety, and protecting against wrongful convictions without burdening the state to compensate all acquitted defendants. This legal clarification tightens the scope for compensation claims to prevent frivolous or unfair awards against judicial decisions made in good faith.
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