Case Digest (G.R. No. 204891)
Facts:
People of the Philippines v. Reynaldo Abayon y Aponte, G.R. No. 204891, September 14, 2016, Supreme Court Second Division, Brion, J., writing for the Court.The appellant, Reynaldo Abayon y Aponte (Abayon), was charged by information dated July 29, 2002 with having willfully and unlawfully burned a dwelling and, as a result, causing the deaths of Lourdes Chokilo, Aiza Delos Angeles and Zenaida Velos — an offense framed under Section 1, in relation to Section 5, of P.D. No. 1613, as amended by R.A. No. 7659. Abayon pleaded not guilty at arraignment on August 20, 2002.
At trial the prosecution presented eyewitness testimony and documentary stipulations. The factual montre revealed a violent quarrel between Abayon and his wife on the evening of July 25, 2002; neighbors Corazon Requitillo and Robert Ignacio intervened. Later that night Ignacio and others smelled leaking LPG gas and saw Abayon holding an LPG tank while muttering, holding a match and an unlit cigarette; Ignacio seized the tank and brought it to safety. At past midnight on July 26, 2002 a fire erupted in the house, razing rooms and killing three persons. Abayon denied guilt and raised an alibi, claiming he had left to look for his family in Trece and Makati; his sister did not corroborate his alibi.
The Regional Trial Court (RTC), Branch 275, Las Piñas City, rendered a decision dated July 31, 2007 finding Abayon guilty beyond reasonable doubt of arson resulting in multiple homicide and sentencing him under Section 5 of P.D. No. 1613. The Court...(Subscriber-Only)
Issues:
- Was the conviction of Abayon supported by sufficient evidence, in particular circumstantial evidence and positive identification?
- Whether the deaths resulting from the fire establish a complex crime of arson with homicide or are absorbed by the crime of arson?
- What are the proper penalty and civil damages...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
- (Subscriber-Only)