Leyson v. Lawa
REITERATIONFacts
The Antecedents: An Information for arson was filed against petitioners Eduardo Leyson, Sr., Eduardo Bantulo, Dominador Bantulo, Eduardo Padayag, Eddie Padayag, and Rodolfo Padayag. The Information alleged that on September 7, 1996, at around 10:00 a.m., in Nopol, Conel, General Santos City, the accused, conspiring and confederating, willfully, unlawfully, and feloniously set fire to thirteen houses belonging to the complainants, causing damages amounting to P468,490.00. Procedural History: The Regional Trial Court (RTC) found Dominador Bantulo, Eduardo Bantulo, Eduardo Padayag, Eddie Padayag, and Rodolfo Padayag guilty of arson and sentenced them to an indeterminate penalty. Eduardo Leyson, Sr. was acquitted on the ground of reasonable doubt but was ordered to pay, jointly and severally with the convicted accused, the actual damages sustained by the private complainants. The Court of Appeals (CA) affirmed the RTC decision but modified the penalty for the convicted accused to reclusion perpetua. The CA rejected the defenses of denial and alibi, finding the testimonies of prosecution witnesses credible. The Petition: Petitioners filed a Petition for Review on Certiorari, arguing that the CA erred in finding that the identities of the persons who burned the houses were clearly established and that the conviction of the Bantulo and Padayag brothers was based on doubts. They also contended that Eduardo Leyson, Sr. should not be held civilly liable.
Issue(s)
Whether the prosecution proved the guilt of petitioners (except Leyson) for the crime of arson beyond reasonable doubt. Whether petitioner Eduardo Leyson, Sr. is civilly liable for the damages to the private complainants.
Ruling
The petition is DENIED. The Decision of the Court of Appeals is AFFIRMED. Costs against petitioners.
Ratio Decidendi
On the guilt of petitioners (except Leyson) for arson: The Court affirmed the findings of the RTC and CA, holding that the prosecution sufficiently proved the guilt of the accused beyond reasonable doubt. The Court emphasized that the findings of the trial court, affirmed by the CA, are accorded high respect and are considered conclusive absent clear evidence of misinterpretation or misapprehension of facts. The Court rejected the petitioners' argument that inconsistencies between witness testimonies and their affidavits should discredit them, citing that affidavits are often incomplete and inferior to testimony in open court. The principle of falsus in uno, falsus in omnibus was deemed not strictly applicable, allowing for the belief of certain parts of a witness's testimony while disbelieving others. The Court found that the testimonies of Romeo Jarmin and Bonifacio Batata, when considered in their entirety, established the conspiracy and the commission of the crime by the petitioners. The Court noted that even if only one person physically set the fire, all conspirators are liable for the acts of one another. The alibi and denial of the petitioners were considered weak defenses against the positive testimonies of the eyewitnesses. On the civil liability of petitioner Eduardo Leyson, Sr.: The Court affirmed the ruling of the CA that petitioner Leyson is civilly liable despite his acquittal on reasonable doubt for the crime of arson. The Court reiterated the rule that acquittal on reasonable doubt does not bar a civil action for damages unless the fact from which the civil liability might arise did not exist, which was not the case here as the houses were indeed burned. Furthermore, the Court pointed to Leyson's admission that he would pay for the damages sustained by the private respondents as an additional basis for his civil liability. The Court found that Leyson's presence at the ranch with his co-petitioners, his order to intimidate the private respondents, and his subsequent offer to pay for the damages supported his civil liability.
Main Doctrine
The testimonies of witnesses, when considered in their entirety and not in truncated parts, are given high respect. Inconsistencies on minor or peripheral matters do not necessarily discredit a witness, especially when affidavits are often incomplete or inaccurate compared to testimony in open court. The principle of falsus in uno, falsus in omnibus is not strictly applied, allowing for belief in some parts of a testimony and disbelief in others. Acquittal on reasonable doubt does not bar civil liability, especially when the accused acknowledges responsibility or obligation to pay damages.