Criminal Law 2 – Assignment 09

Grace Dela Rama, JD1-A

Maderazo v. People
G.R No. 165065, September 26, 2006

Facts:
The victim was the lessee of the stall in the Public Market where she paid a
monthly rental of P200.00. She was allowed to finish the construction of the
market stall with the permission of the Mayor and Municipal Treasurer with an
agreement that expenses shall be reimbursed. She was not however, reimbursed by
the Municipality of her expenses. After the construction, she opened the stall for
business paid the rent for the whole year of 1992 but did not pay the rentals in
1993. Considering that she had not been fully reimbursed of her expenses for the
construction of the stall, she did not pay her rent. Fully aware that the Municipality
still owed the victim money, the treasurer did not collect her rentals.
The victim did not pay open her stall during the Christmas holidays
however, when came back, she received a letter-order from the Mayor directing
her to vacate the stall within 24-hours due to her failure to pay the rentals. It was
said that she has unpaid rentals after deducting her expenses for the construction of
the stall and the Mayor declared the contract of lease cancelled. Due to the refusal
of the victim to vacate the stall, the Mayor padlocked the leased premises and the
locks were just opened on the authority of the Mayor, the contents of which were
inventoried and taken to the police station for safekeeping.
Hence, a complaint for grave coercion was filed against Mayor Maderazo.
Sandiganbayan convicted the accused of the crime unjust vexation.

Issue:
Is the accused guilty of the crime grave coercion as alleged in the
information?

Ruling:
No, the Court affirmed the Ruling of Sandiganbayan that the accused is
guilty of the crime Unjust Vexation. The accused cannot be convicted of grave
coercion because they did not use violence, threat, or intimidation. The victim
could not have possibly been intimidated or forced by the accused, as she was not
at the market stall when the same was padlocked, and its goods inventoried and
hauled. Although the victim was not at her stall when it was unlocked, and the
contents thereof taken from the stall and brought to the police station, the crime of
unjust vexation was nevertheless committed. For the crime to exist, it is not
necessary that the offended party be present when the crime was committed by said
petitioners. It is enough that the private complainant was embarrassed, annoyed,
irritated, or disturbed when she learned of the overt acts of the petitioners. Indeed,
by their collective acts, accused evicted the victim from her stall and prevented her
from selling therein, hence, losing income from the business.