HAGÅTÑA (The Guam Daily Post) — The Supreme Court of Guam affirmed the conviction and 25-year sentence for a man found guilty in the 2020 killing of 45-year-old Peter John Tadeo Rios Jr.
On Tuesday, the Supreme Court of Guam issued an opinion in an appeal for Juan Faisao Mendiola, who was found guilty of manslaughter in connection to Rios’ death.
Mendiola, who was sentenced to serve 25 years in prison last January, argued for a reversal of his conviction and sought a new trial on the grounds his rights were deprived due to his trial being held during the COVID-19 pandemic. Additionally, Mendiola argued his actions in the killing of Rios were protected by the Castle Doctrine and claimed he was acting in self-defense.
During the oral arguments held in April this year, inside the John F. Kennedy High School gymnasium as part of the annual celebration of Law Month, the prosecution argued if Mendiola’s conviction were to be reversed because of the pandemic conditions, other trials could be at risk.
COVID-19
Mendiola argued he did not receive a public trial due to the COVID-19 protocols that were in place when it took place in September 2021, and it violated his Sixth Amendment right to a “speedy and public trial.”
However, as argued by the prosecution, Mendiola should have objected to the trial conditions in a timely fashion, which Chief Justice Robert Torres and Associate Justices Philip Carbullido and Katherine Maraman agreed with considering Mendiola did not make an objection until after a jury was selected.
As for closing the trial to the public due to the COVID-19 pandemic, the justices agreed that was an error. However, they said that there was a need to protect the public’s interest of health and safety.
“As to the closure of (the) trial, the court held that the trial court did not violate Mendiola’s Sixth Amendment right because the closure was narrowly tailored to an overriding public health interest, and the trial court considered reasonable alternatives and made adequate findings,” a Judiciary of Guam press release stated.
Castle Doctrine
Mendiola relied on the Castle Doctrine in his claim for self-defense, which he argued was “not disproven beyond a reasonable doubt,” the opinion states.
The justices disagreed with the argument because, despite Mendiola’s claims, the jury was correctly instructed that it was the prosecution’s burden to disprove the self-defense claim beyond a reasonable doubt.
The opinion then further reviewed whether there was sufficient evidence provided by the prosecution that Mendiola wasn’t acting in self-defense.
Mendiola’s charge stems from Rios being found dead inside a Mongmong apartment on May 4, 2020. Despite Mendiola being accused of shooting and killing Rios, he presented his theory during trial that Rios was the initial aggressor. Additionally, according to the opinion, Mendiola presented evidence that Rios had a violent history and that Mendiola “reasonably feared for his safety and life.”
In response, the prosecution presented evidence that contradicted Mendiola’s claim and argued Mendiola went to get the firearm before Rios threatened him, Rios was not violent, another individual tried to get between the two before Mendiola fired the gun and Mendiola shot Rios again after he was already dead on the floor, the opinion states.
“Viewing the evidence in the light most favorable to the people, a rational trier of fact could have found that Mendiola did not act in self-defense. The evidence is sufficient to contradict any assertion of self-defense beyond a reasonable doubt,” the justices wrote before concluding they affirmed Mendiola’s conviction.
Juan Faisao Mendiola
