Mohammad v. Office of the Secretary
REITERATIONFacts
The Antecedents: On September 18, 2017, petitioner Main T. Mohammad was arrested, detained, and charged with piracy and two counts of murder. He was identified as a member of the Abu Sayyaf Group (ASG) responsible for various kidnappings and killings. However, on April 8, 2019, the Regional Trial Court (RTC) dismissed the murder charges because the prosecution was unable to produce a witness who could identify Mohammad as the person charged in the Information. Mohammad claimed he was a victim of mistaken identity and had been unjustly detained for two years for crimes he did not commit. Procedural History: Following his acquittal, Mohammad filed a claim for compensation under Republic Act No. 7309 with the Department of Justice (DOJ) Board of Claims. The Board denied the claim on November 18, 2020, citing a lack of prior conviction, as the law requires a conviction in the trial court followed by an acquittal on appeal. Mohammad appealed to the Office of the Secretary of Justice, which affirmed the Board's decision on February 1, 2021, ruling that the conjunctive 'and' in Section 3(a) requires all elements to concur and that the classification was constitutional. The Petition: Mohammad filed a Petition for Certiorari under Rule 65 before the Supreme Court, arguing that the Secretary of Justice acted with grave abuse of discretion. He contended that the term 'and' in Section 3(a) should be construed disjunctively as 'or' to avoid absurdity and injustice. He further challenged the constitutionality of the provision, asserting that excluding those acquitted at the trial court level from compensation violates the Equal Protection Clause of the Constitution.
Issue(s)
Whether the Secretary of Justice committed grave abuse of discretion in denying the claim for compensation under Section 3(a) of Republic Act No. 7309 for lack of prior conviction. Whether Section 3(a) of Republic Act No. 7309 violates the Equal Protection Clause of the Constitution.
Ruling
The Petition is DENIED. The Decision of the Secretary of Justice is AFFIRMED.
Ratio Decidendi
On Issue 1: The Court held that the Secretary of Justice did not commit grave abuse of discretion because the denial was based on the clear and literal import of Section 3(a) of Republic Act No. 7309. Applying the principle of 'Verba Legis,' the Court ruled that the word 'and' is a conjunctive term denoting a joinder or union, meaning the elements of being unjustly accused, convicted, and imprisoned are cumulative. In Mohammad's case, the element of prior conviction was absent because he was acquitted at the first instance by the trial court. Furthermore, citing Basbacio v. Drilon, the Court emphasized that an accusation based on 'probable guilt' is not an 'unjust' accusation, but merely an 'erroneous' one, which does not entitle a person to compensation. The Court noted that Mohammad's detention was proper given that he was charged with non-bailable offenses, and the failure of the prosecution to identify him did not automatically render the initial accusation 'unjust.' On Issue 2: The Court sustained the constitutionality of Section 3(a) of Republic Act No. 7309, ruling that it does not violate the Equal Protection Clause. It held that there is no constitutional requirement that a regulation must reach every class to which it may be applied, and the legislature has the discretion to set parameters for compensation. Citing Quinto v. Commission on Elections, the Court stated that in the absence of a showing of arbitrariness, the classification must be sustained even if its reasonableness is 'fairly debatable.' The Court acknowledged the systemic issue of 'Muslim profiling' and 'mistaken identity' as discussed in the reflections of Senior Associate Justice Leonen, but concluded that it cannot overstep its bounds by amending legislation through judicial interpretation to address perceived gaps in the law's coverage.
Main Doctrine
The principle of 'Verba Legis' dictates that when the language of a statute is clear and free from ambiguity, it must be applied according to its literal meaning without room for interpretation. In Section 3(a) of Republic Act No. 7309, the word 'and' is used to bind the elements of unjust accusation, conviction, and imprisonment, signifying that these requisites are cumulative. Consequently, a claimant must demonstrate that they were not only unjustly accused and imprisoned but also convicted by a trial court and subsequently released by virtue of a judgment of acquittal, typically on appeal. An accusation based on 'probable guilt' is merely erroneous, not 'unjust,' and does not satisfy the statutory requirements for state compensation.