Case Digest: Encarnacion Go v. People of the Philippines G.R. No. 249563, March 9, 2022 Supreme Court, Second Division Ponente: Justice Ricardo R. Rosario

 The Supreme Court GRANTED the petition and REVERSED AND SET ASIDE the Decision and Resolution of the Court of Appeals. It ACQUITTED Encarnacion Go on the ground that the prosecution failed to prove her guilt beyond reasonable doubt. The Court held that while the Information sufficiently alleged the elements of the offense under Section 92 of Republic Act No. 8550 (The Philippine Fisheries Code of 1998), the evidence presented during trial failed to establish that the fishing operation actually employed the prohibited muro-ami method. The Court explained that the sufficiency of an Information is determined by whether it alleges the essential elements of the offense so as to adequately inform the accused of the nature and cause of the accusation, thereby satisfying the constitutional right to due process.

The Court found that the prosecution failed to present competent and convincing evidence proving that the fishing vessel used muro-ami as defined by law. The testimonies of the prosecution witnesses were inconsistent and failed to clearly establish that the fishing operation involved the use of divers pounding coral reefs or employing the destructive techniques specifically prohibited under Section 92 of R.A. No. 8550. The Court stressed that criminal convictions must rest on proof beyond reasonable doubt and not on presumptions or speculation. The prosecution's evidence was insufficient to overcome the constitutional presumption of innocence.

The Court likewise ruled that the prosecution failed to prove that petitioner knowingly participated in or authorized the alleged illegal fishing operation. Mere association with the fishing vessel or the corporation that owned it did not automatically establish criminal liability. The Court emphasized that every element of the offense, including the accused's participation in the prohibited act, must be proven by competent evidence. Since the prosecution failed to discharge this burden, petitioner was entitled to an acquittal.

Accordingly, the Supreme Court acquitted Encarnacion Go of the charge for Violation of Section 92 of Republic Act No. 8550. The Court reiterated that although the State has a strong interest in protecting marine resources and preventing destructive fishing practices pursuant to Article II, Section 16 of the 1987 Constitution, criminal liability cannot be imposed absent proof beyond reasonable doubt. The constitutional presumption of innocence must prevail where the evidence leaves reasonable doubt as to the accused's guilt.