Title
Bacolod vs. People
Case
G.R. No. 206236
Decision Date
Jul 15, 2013
Gilfredo Bacolod convicted of arson based on circumstantial evidence; penalty corrected, temperate damages awarded to victims. SC affirmed conviction, emphasizing sufficiency of circumstantial evidence and judicial duty to impose proper penalties and civil liability.
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Case Digest (G.R. No. 206236)

Facts:

  1. Conviction by the RTC: On March 31, 2008, the Regional Trial Court (RTC), Branch 9, Cebu City, convicted Gilfredo Bacolod (a.k.a. Gilardo Bacolod) of arson. He was sentenced to 10 years of prision mayor (medium period) as minimum to 16 years of reclusion temporal (medium period) as maximum.
  2. Affirmation by the CA: On December 9, 2011, the Court of Appeals (CA) affirmed the RTC's decision in full.
  3. Circumstantial Evidence: The prosecution relied on circumstantial evidence, including witness testimonies. Ruben Gonzales testified that he heard the petitioner demanding money from his sister, Daisy Mae Bacolod, inside the rented house of Spouses Ceferino and Gemma Cogtas. He later saw the petitioner waving a flaming blanket in the kitchen, which caused the house to burn down.
  4. Civil Liability Omission: The RTC and CA failed to award civil liability to the Spouses Cogtas for the damage caused by the arson, despite evidence of economic loss.

Issue:

  1. Sufficiency of Evidence: The petitioner argued that the conviction was based solely on circumstantial evidence, which he claimed was insufficient to prove guilt beyond reasonable doubt.
  2. Proper Penalty: The petitioner questioned whether the penalty imposed by the RTC and affirmed by the CA was correct under the law.
  3. Civil Liability: The Court raised the issue of whether the RTC and CA erred in failing to award civil liability to the Spouses Cogtas for the damage caused by the arson.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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