People v. De Leon
REITERATIONFacts
The Antecedents: On April 5, 1986, at around 8:30 in the evening, Aquilina Mercado Rint and her sister Leonisa Mercado, along with their nephew Narciso Mercado Jr., were inside a hut owned by their father, Rafael Mercado. Prompted by their dog's barking, Aquilina saw five men, including Gaudencio Legaspi and the appellants, approaching the premises. Aquilina and Leonisa hid while Junior was sent to call for help. From their hiding place, they witnessed the appellants surround the hut and set fire to its cogon roofing. Leonisa used a flashlight to illuminate the group, prompting Gaudencio to order their escape. By the time Junior returned with his uncles, the hut was completely destroyed. The prosecution alleged that prior to the incident, the appellants had destroyed plants, a fence, and a previous hut on the premises, and had threatened Rafael Mercado, leading to several cases filed by Rafael against the appellants. Procedural History: An Information was filed charging Gaudencio Legaspi and the appellants with arson. Gaudencio Legaspi died before arraignment. The appellants pleaded not guilty. The Regional Trial Court (RTC) of Nueva Ecija found the appellants guilty beyond reasonable doubt of arson and sentenced them to an indeterminate prison term and to pay damages. The Court of Appeals (CA) affirmed the RTC decision with modification, sentencing the appellants to suffer the penalty of reclusion perpetua and awarding temperate and exemplary damages. The Petition: The appellants appealed the CA decision to the Supreme Court.
Issue(s)
Whether the prosecution sufficiently proved the guilt of the appellants beyond reasonable doubt for the crime of arson. Whether the penalty of reclusion perpetua was correctly imposed. Whether the award of temperate and exemplary damages was proper.
Ruling
The Supreme Court denied the appeal, affirming the decision of the Court of Appeals which found the appellants guilty beyond reasonable doubt of arson, sentenced them to suffer the penalty of reclusion perpetua, and ordered them to pay the heirs of Rafael Mercado P2,000.00 as temperate damages and P20,000.00 as exemplary damages.
Ratio Decidendi
On the guilt of the appellants for arson: The Court held that the prosecution successfully established the two essential elements of arson: (a) intentional burning and (b) that the object intentionally burned was an inhabited house or dwelling. The testimonies of prosecution witnesses Aquilina and Leonisa Mercado were found to be credible and were positively corroborated by the circumstances. Their positive identification of the appellants, despite the appellants' denial and alibi, prevailed. The Court reiterated the principle that factual findings of the trial court on the credibility of witnesses are entitled to the highest respect and will not be disturbed on appeal unless there is a clear showing of oversight or misapplication of facts. The corpus delicti, or the fact that a crime has been committed, was proven by the charred remains of the house and evidence of intentional burning. On the penalty of reclusion perpetua: The Court affirmed the imposition of reclusion perpetua, which is the penalty for arson when the property burned is an inhabited house or dwelling, as provided by Section 3 of Presidential Decree No. 1613. Furthermore, Section 4 of the same decree mandates the imposition of the penalty in its maximum period if the crime is committed by a syndicate, defined as a group of three or more persons. The Court found that the crime was carried out by a group of more than three persons, thus justifying the imposition of the penalty in its maximum period, which is reclusion perpetua. On the award of damages: The Court found the award of temperate damages in the amount of P2,000.00 to be correct, as it is awarded when the exact amount of loss cannot be determined but the court is convinced that loss occurred. The award of exemplary damages in the amount of P20,000.00 was also deemed appropriate in view of the presence of the special aggravating circumstance of the crime being committed by a syndicate, which warrants the imposition of the penalty in its maximum period.
Main Doctrine
The elements of arson are (a) intentional burning and (b) that the object intentionally burned is an inhabited house or dwelling. The penalty of reclusion perpetua shall be imposed if the property burned is an inhabited house or dwelling, and the maximum period shall be imposed if the crime was committed by a syndicate.