People v. Lorenzo
REITERATIONFacts
The Antecedents: On April 7, 1987, a group of approximately seventy persons, suspected to be members of the New People's Army (NPA), attacked the house and rice granary of Albino C. Miranda. They fired upon the house and demanded Miranda to come out. When Miranda refused, they set fire to his rice granary and subsequently his house, which was occupied by him and his family. The fire completely destroyed the house and its contents, including palay, furniture, cash, and other properties, with a total estimated value of P153,980.00. Procedural History: Orlando Arbolante y Lagundi, Teodulfo Lorenzo (appellant), and Maximo Catabay were charged with arson under Presidential Decree No. 1613. Arbolante and Lorenzo pleaded not guilty, while Catabay remained at large. After trial, the Regional Trial Court (RTC) of Tuao, Cagayan, Branch XI, convicted Arbolante and Lorenzo of arson, sentencing them to suffer the penalty of reclusion perpetua and to pay civil liability jointly and solidarily. Arbolante jumped bail before the promulgation of the decision. The Petition: Teodulfo Lorenzo appealed his conviction, assigning errors related to the trial court's reliance on inconsistent and incredible testimonies of prosecution witnesses, the weakness of defense evidence, and the failure to acquit him on reasonable doubt.
Issue(s)
Whether the inconsistencies in the testimonies of prosecution witnesses affect their credibility. Whether the defense of alibi and denial can prevail over the positive identification by prosecution witnesses. Whether the accused-appellant conspired with others to commit arson. Whether the damages awarded by the trial court are supported by evidence.
Ruling
The Supreme Court affirmed the decision of the trial court, finding the accused-appellant guilty of arson. However, the Court modified the civil liability, reducing the total amount to P153,000.00. The penalty of reclusion perpetua was upheld.
Ratio Decidendi
On the credibility of prosecution witnesses and inconsistencies: The Court held that inconsistencies in minor details do not affect the credibility of witnesses, especially when their narration is coherent and intrinsically believable. The discrepancies between Albino Miranda's and Violeta Miranda's testimonies regarding the exact location where the fire started (wall vs. kitchen roof) and the exchange of gunfire were explained as natural variations in human perception and experience. The Court reiterated that such minor variations can even show sincerity and absence of connivance. The doctrine of falsus in uno, falsus in omnibus was deemed inapplicable as the core fact of the crime being committed by identified perpetrators remained trustworthy. On the defenses of alibi and denial: The Court found the accused-appellant's defenses of alibi and denial to be weak and easily defeated by the positive identification made by prosecution witnesses. The accused-appellant's testimony regarding his whereabouts on the night of the incident was found to be vacillating and contradictory, particularly when questioned by the trial court. The Court emphasized that positive identification by credible witnesses prevails over bare denials and alibis, which are inherently weak defenses that can be easily fabricated. On conspiracy and the commission of arson by a syndicate: The Court found ample basis to infer the presence of conspiracy from the acts of the accused-appellant and his co-accused, especially considering the information alleged that the crime was committed by a syndicate of approximately seventy persons. The Court noted that the offense is committed by a syndicate if planned or carried out by a group of three or more persons. The unity of action and purpose, or common design, was inferred from the circumstances, making the act of one conspirator the act of all. On the amount of damages: The Court modified the civil liability awarded by the trial court. While acknowledging the total value of properties burned as P153,980.00 in the information, the Court found that only P153,000.00 was sufficiently proven as damages. Specifically, the Court noted that the information valued the 149 cavans of palay at P18,000.00, even though Corporal Fernandez estimated it at P18,680.00, and that only P700.00 was proven for kitchen wares, despite the information stating P1,000.00. The Court ruled that it cannot grant more than what was claimed in the information and proven during trial.
Main Doctrine
Positive identification of the perpetrators by prosecution witnesses prevails over the defenses of denial and alibi. Inconsistencies in minor details do not affect the credibility of witnesses as long as their narration is coherent and intrinsically believable. The crime of arson committed by a syndicate requires proof of conspiracy, where the act of one is the act of all.