Case Digest (G.R. No. 93485)
Facts:
People of the Philippines v. Pedro Cedenio y Rasonable, Felipe Antipolo y Misa, and Jurito Amarga y Bahi-an, G.R. No. 93485, June 27, 1994, the Supreme Court First Division, Bellosillo, J., writing for the Court.On the night of 26 November 1986 the house of Hilario Dorio in Gandingan, Pangantucan, Bukidnon, was set afire; when the blaze subsided five members of the Dorio household were found dead, including a 22‑day‑old infant. Several neighbors — Bonifacio Palomas, Policarpio Apostadero and barangay officials — testified that at about 10:30 p.m. they saw about seven persons emerge from the burning house, among them appellants Pedro Cedenio, Jurito Amarga and Felipe Antipolo, wielding unsheathed bolos. The next morning the witnesses joined others at the scene and observed the charred bodies; four of the victims bore stab and hack wounds while the infant showed no external wounds but was incinerated.
Another prosecution witness, Perfecto Antifuesto, testified that Cedenio had borrowed his bolo the evening of the fire and that the bolo was returned early the next morning with bloodstains on its handle and blade; Cedenio allegedly told Antifuesto not to worry and that he would "answer for everything" if the matter reached court. Nine persons were originally charged; two remained at large and four others were dropped for insufficiency of evidence; only the three appellants were eventually tried.
The Regional Trial Court, Branch 8, Malaybalay, Bukidnon (Judge Vivencio P. Estrada) found appellants guilty on 16 March 1990 of "Arson with Multiple Murder as defined and penalized under Section 5 of Presidential Decree No. 1613" and sentenced them to reclusion perpetua; they filed a notice of appeal on 4 April 1990. The appellants argued on appeal that the evidence was circumstantial and insufficient, that sightings of them leaving the burning house were consistent with attempts to save lives, that the bolo testimony was improbable, and that their denials and alibis should prevail.
The Supreme Court reviewed the record, treated the Information's labeling of the off...(Pro-only)
Issues:
- Was the evidence sufficient to sustain convictions against appellants for the crimes charged?
- Can the crime charged as "arson with multiple murder" be treated as separate crimes of murder and arson, and do the facts show treachery or evident premeditation?
- What are the proper penalties and civil liabilities ari...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)