SC upholds strict criteria for unjust jail claims

The Supreme Court ruled that to qualify for compensation under Section 3(a) of Republic Act (RA) 7309, an individual must have been unjustly imprisoned following a conviction.

In a decision authored by Associate Justice Maria Filomena D. Singh dated 27 February and published on 12 July, the Supreme Court En Banc upheld the Department of Justice Board of Claims’ decision to deny Main T. Mohammad's compensation claim.

Records indicate that Mohammad was arrested, detained, and charged with piracy and two counts of murder in 2017, as he was identified as a member of the Abu Sayyaf Group. In 2019, these charges were dismissed when the prosecution failed to produce a witness who could identify Mohammad as the person named in the charges.

Mohammad subsequently filed a claim for compensation before the Board in Zamboanga City, invoking Section 3(a) of RA 7309, which provides compensation to individuals "unjustly accused, convicted, and imprisoned but released by virtue of a judgment of acquittal."

Mohammad argued that the conjunction "and" in Section 3(a) should be interpreted as "or" to prevent injustice to those unjustly prosecuted but later acquitted.

However, the Board denied his claim, stating that both prior conviction in trial court and subsequent release due to acquittal on appeal are necessary.

The Justice Secretary affirmed the Board's decision, leading Mohammad to file a petition for certiorari under Rule 65 of the Rules of Court.

The Court denied Mohammad's petition, ruling that to qualify for compensation under Section 3(a) of RA 7309, an individual must meet all specified criteria: being unjustly accused, convicted, imprisoned due to that conviction, and subsequently acquitted by a judgment.

The Court emphasized that these elements are cumulative, as indicated by the conjunction "and," which signifies the connection of words or phrases.

In Mohammad's case, the Court found all these elements lacking. Regarding the first element, there was insufficient evidence to show unjust accusation beyond Mohammad's detention for two years before acquittal.

The Court stressed that without malicious intent from the prosecution, an accusation based on probable guilt leading to acquittal may be erroneous but not necessarily unjust.

Furthermore, since there was no conviction due to the dismissal of charges, the last two elements were also absent.

The Court concluded that while it aims for judicial reforms toward a fair and just society for all, it cannot amend existing legislation to address perceived injustices beyond its mandate.