When does presumption of innocence end?
Where the conviction by a lower court is still on appeal, it has not yet reached finality and the accused still enjoys the constitutional presumption of innocence. It must be remembered that the existence of a presumption indicating the guilt of the accused does not in itself destroy the constitutional presumption of innocence unless the inculpating presumption, together with all the evidence, or the lack of any evidence or explanation, proves the accused's guilt beyond a reasonable doubt. Until the accused's guilt is shown in this manner, the presumption of innocence continues. Thus in Mangubat v. Sandiganbayan, the Court held that respondent Sandiganbayan did not act with grave abuse of discretion, correctible by certiorari, when it ruled that despite her conviction, the accused still enjoyed presumption of innocence.
Re: Judge Angeles, A.M. No. 06-9-545-RTC, January 31, 2008.
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