Case Digest (G.R. No. 159950)
Facts:
Joel P. Gonzales, Jr. v. The People of the Philippines, G.R. No. 159950, February 12, 2007, Supreme Court Second Division, Quisumbing, J., writing for the Court.Petitioner Joel P. Gonzales, Jr. was charged by Information dated July 24, 1997 with arson for allegedly setting fire on June 26, 1997 to a two‑storey residential building partitioned into dwellings and owned/occupied by Carlos C. Canlas in Quezon City, resulting in claimed aggregate damages of P5,465,000. On arraignment petitioner pleaded not guilty.
At trial before the Regional Trial Court (RTC) of Quezon City, Branch 97, the prosecution presented eyewitness Carlos C. Canlas, tenants Andres V. Villaflor and Francis F. Simpao, and Police Officer Alejandro Mendoza. Canlas testified that at about 9:30 p.m. he smelled gas, saw Gonzales ignite a flame and throw it on a pile of clothes near an LPG tank; the fire quickly spread. Villaflor testified he heard Gonzales threaten to burn the house during a quarrel and later found it on fire; Simpao said he saw the fire originate from Gonzales’s room and that Gonzales laughed while the building burned. Mendoza testified that Gonzales admitted responsibility at the scene.
Petitioner denied culpability, claiming the fire resulted from faulty wiring; he testified he was asleep and awoke to find his room on fire and that his aunt and neighbors wrongly accused him. As defense evidence, petitioner offered a Physical Science Report by Police Inspector Grace M. Eustaquio showing that ashes from the premises tested negative for any flammable substance.
On May 28, 1998, the RTC convicted petitioner of arson and sentenced him to imprisonment and awarded nominal damages of P10,000 each to Canlas, Villaflor and Simpao. Petitioner appealed to the Court of Appeals (CA).
In its Decision dated March 11, 2003 (CA‑G.R. CR No. 22157), the Court of Appeals affirmed the RTC, finding that discrepancies between Canlas’s prior sworn statements and his trial testimony were not material and that, together with corroborating testimony and petitioner’s admission at the scene, the evidence established guilt beyond reasonable doubt. Gonzales’s motion for reconsideration was denied.
Petitioner filed a petition for review on certiorari to the Supreme Court (for review on certiorari of the CA Decision), urging t...(Pro-only)
Issues:
- Did the Court of Appeals correctly uphold the trial court’s credibility determinations despite discrepancies between prosecution witnesses’ affidavits and their testimony in court?
- Did the Court of Appeals correctly affirm petitioner’s conviction for arson on the present record, and what penalties and da...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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