Case Digest (G.R. No. 185282)
Facts:
People of the Philippines v. Benjamin Bravo y Estabillo, G.R. No. 185282, September 24, 2012, Supreme Court Second Division, Perez, J., writing for the Court. The case is an appeal from the Court of Appeals Decision of 27 May 2008 affirming the conviction by the Regional Trial Court (RTC) of Bauang, La Union, Branch 33, for arson.The Information, filed 17 August 1989, charged Benjamin Bravo y Estabillo (appellant) with arson with double murder for the burning of the house of Mauro Camacho on 10 August 1989 at about 9:30 p.m., which allegedly resulted in the instantaneous deaths of Shirley Camacho and her four‑month‑old son Jerickson. The complaint alleged that appellant, motivated by anger and accusing the Camachos of witchcraft, threatened to burn them and that a fire followed shortly after his departure from the Camacho house.
At trial the prosecution presented eyewitnesses who testified that appellant came to the Camacho house that night, pointed a long firearm at Mauro, demanded that Mauro produce an “akusan” (an object used in witchcraft), threatened “I will burn you all. All of you will die,” then descended the stairs; about fifteen seconds later a fire broke out in Shirley’s room and spread, consuming the house and killing Shirley and her infant. Other witnesses saw appellant running near the scene carrying a long firearm shortly after gunshots and the outbreak of the fire. Photographs, charred remains, and a list of burned belongings were introduced.
Appellant pleaded alibi, testifying that he accompanied his father to San Fabian for faith‑healing and slept there the night of the incident, and presented family members and community leaders to corroborate his good character and presence in San Fabian. The RTC, presided by Judge Rose Mary R. Molina Alim, found appellant guilty by reliance on circumstantial evidence and convicted him of arson in a Decision dated 16 July 2002, sentencing him to reclusion perpetua and awarding civil indemnities and moral and nominal damages.
The Court of Appeals affirmed the RTC’s factual findings and conviction in its 27 May 2008 Decision, agreeing that circumstantial evidence formed an unbroken chain identifying appellant as the arsonist, and modified the damages award by adding exemplary damages of P50,000 to one of the offended parties. Appellant sought review before this Court; the record shows the Court required supplemental briefs on 19 Ja...(Subscriber-Only)
Issues:
- Was the circumstantial evidence sufficient to establish appellant’s guilt beyond reasonable doubt?
- Did appellant’s alibi create reasonable doubt requiring acquittal?
- Is imposition of reclusion perpetua proper in view of the repeal of the death penalty?
- Should the damages and exemplary damages awarded by the ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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