G.R. No. 93485 - People vs. Cedenio y Rasonable

On November 26, 1986, at around 10:30 PM, Bonifacio Palomas was awakened by noises and cries for help from Hilario Dorio’s house, approximately 30 meters away. He saw the house on fire and observed about seven persons, including appellants Pedro Cedenio, Felipe Antipolo, and Jurito Amarga, emerging from the burning house holding unsheathed bolos.
Palomas stayed inside out of fear. The following morning, he went with Romeo Dorio, Hilario's son, to the site where they saw the charred bodies of Hilario Dorio, Flora Dorio, Maria Dorio, Dioscora Dorio (a 22-day-old infant), and Nicanora Tabanao, an alleged family of sorcerers.

Policarpio Apostadero was resting when he heard dogs barking and noticed the burning house about 30 meters away. He saw people fleeing the burning house and recognized Cedenio, Amarga, and Antipolo holding bloodstained bolos. He then went home to avoid confrontation.
Barangay Captain Albino Calunod, Sr. was informed early morning about the incident. Upon arriving at the scene, he found the house completely burned and five bodies with various wounds.
Perfecto Antifuesto testified that around 7 PM on November 26, Cedenio borrowed his bolo, which was returned at around 3 AM the next day with fresh blood stains on its blade and handle. Cedenio reportedly assured him not to worry about any court case arising from the incident.

Although nine persons were initially implicated, only three appellants were convicted. The others were either at large or dropped for insufficient evidence.
On March 16, 1990, the trial court found the appellants guilty of "Arson with Multiple Murder" under Section 5 of Presidential Decree No. 1613, sentencing each to reclusion perpetua. The appellants appealed the decision.

Appellants argued there was no direct evidence linking them to the killings or arson.
They contended their presence at the scene was to save lives and property, not to commit the crime. For instance, Cedenio claimed to have thrown banana trunks into the fire, and Antipolo asserted he gathered soil to extinguish it.
They questioned the credibility of Antifuesto’s testimony about the bolo being borrowed and returned with blood, explaining it as illogical to carry a weapon used in a crime openly.
They also relied on their denial and alibi to challenge prosecution evidence.

Whether the appellants are guilty beyond reasonable doubt of the crime of arson resulting in death and multiple murders.

Whether the appellants’ presence at the scene could be reasonably interpreted as an attempt to save lives and property or as participation in the crime.

Whether the qualification of the killing as "murder" or "homicide" can be made considering the circumstances and evidence.

Whether the penalty and charge of "Arson with Multiple Murder" under P.D. No. 1613 is valid and correctly applied.